IR 05000338/2011000

IR 05000338-11-00, 0500339-11-003 and 0720056-11-001; 04/01/2011 - 06/30/2011; North Anna, Units 1 and 2. Routine Integrated Inspection Report. Fire Protection. Plant Modifications. Identification and Resolution of Problems. Event Followup

ML112092630
Person / Time
Site:	North Anna
Issue date:	07/28/2011
From:	Gerald Mccoy NRC/RGN-II/DRP/RPB5
To:	Heacock D Virginia Electric & Power Co (VEPCO)
References
IR-11-001, IR-11-003
Download: ML112092630 (43)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION uly 28, 2011

SUBJECT:

NORTH ANNA POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000338, 339/2011003, AND 0720056/2011001

Dear Mr. Heacock:

On June 30, 2011, 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 July 26, 2011, 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 licenses. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents a finding with potentially greater than Green significance. Additionally, a licensee-identified violation which was determined to be of very low safety significance is listed in the report. The report also documents five NRC-identified findings of very low safety significance (Green) which were determined to be violations of NRC requirements. However, because of the very low safety significance of these issues and because they were entered into your corrective action program, the NRC is treating these as non-cited violations (NCV)

consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you wish to contest these non-cited violations, 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.

Additionally, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region II, and the NRC Resident Inspector at the North Anna Power Station. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.

VEPCO 2 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/

Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket Nos.: 50-338, 50-339, 72-56 License Nos.: NPF-4, NPF-7, SNM-2507

Enclosure:

Inspection Report 05000338/2011003, 339/2011003 and 0720056/2011001 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-338, 50-339, 72-56 License Nos.: NPF-4, NPF-7, SNM-2507 Report No: 05000338/2011003, 05000339/2011003, 0720056/2011001 Licensee: Virginia Electric and Power Company (VEPCO)

Facility: North Anna Power Station, Units 1 & 2 and Independent Spent Fuel Storage Facility Location: 1022 Haley Drive Mineral, Virginia 23117 Dates: April 1, 2011 through June 30, 2011 Inspectors: J. Reece, Senior Resident Inspector R. Clagg, Resident Inspector C. Sanders, Acting Resident Inspector R. Carrion, Senior Reactor Inspector, Section 4OA7 S. Sandal, Senior Reactor Inspector, Section 4OA5.5 D. Mas, Reactor Inspector, Section 4OA5.5 A. Alen, Reactor Inspector, Section 4OA5.5 A. Sengupta, Reactor Inspector, Section 4OA5.5 Approved by: Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 0500338, 339/2011003 and 0720056/2011001; 04/01/2011 - 06/30/2011; North Anna Power

Station, Units 1 and 2. Routine Integrated Inspection Report. Fire Protection. Plant Modifications. Identification and Resolution of Problems. Event Followup. Other Activities.

The report covered a 3 month period of inspection by resident inspectors and reactor inspectors from the region. Five findings were identified and were determined to be non-cited violations (NCVs). Additionally, one finding was identified with potentially greater than Green significance.

The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). The cross-cutting aspect was determined using IMC 0310, Components Within the Cross Cutting Areas. 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.

Cornerstone: Initiating Events

• TBD. A self-revealing finding was identified for the failure to take adequate corrective action for degradation of annunciator card resistors in accordance with the standards as established by the licensees corrective action program procedure which resulted in a fire in the respective annunciator cabinet located in the Units 1 and 2 control room complex. The licensee entered the problem into their corrective action program as condition report 412487.

The finding was more than minor because it could be reasonably viewed as a precursor to a significant event based on fire development leading to an evacuation of the control room. In accordance with NRC IMC 0609, Significant Determination Process, and the associated Appendix F, the inspectors performed a phase 1 analysis and determined the finding would require a Phase 2 analysis be a regional senior reactor analyst because the fire impacts the control room. Consequently, the significance of this finding is TBD pending completion of the significance evaluation.

The cause of this finding involved the cross-cutting area of problem identification and resolution, the component of the corrective action program, and the aspect of appropriate and timely corrective action, P.1(d), because the licensees corrective action plan, in spite of additional failures involving fire precursors, was not timely to preclude a fire event. (Section 4OA3.2)

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation of the North Anna Power Station, Unit 1 Renewed Facility Operating License, NPF-4, Condition 2.D, Fire Protection, which involved a failure to comply with transient fire load procedure requirements that resulted in transient fire loads improperly located in a safety-related area, the Unit 1 motor driven auxiliary feedwater (MDAFW) room, contrary to transient fire load report requirements. The licensee entered the problem into their corrective action program as condition report 423054.

The finding was more than minor because it impacted the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and the related attribute of protection against external factors such as fire. This finding had a credible impact on safety because the transient fire load exceeded the limit of Class B liquid transient loads. In accordance with NRC IMC 0609, Significant Determination Process, Appendix F, the inspectors performed a Phase 1 analysis and determined that the finding was of very low safety significance or Green because although the combustible controls program element was of high degradation due to oily rags in an unapproved container, the Unit 1 MDAFW room had a low fire frequency of 1E-6 and the duration of the violation was less than 3 days, which resulted in a screening check frequency of 1E-8 which was less than the screening criteria of 1E-6. The cause of this finding involved the cross-cutting area of human performance, the component of work practices, and the aspect of procedural compliance, H.4(b), because the licensee failed to follow procedural requirements for the control of transient fire loads in a safety-related area. (Section 1R05.1)

Green.

The inspectors identified a non-cited violation of the North Anna Power Station, Units 1 & 2 Renewed Facility Operating Licenses, NPF-4 & 7, Condition 2.D,

Fire Protection, which involved a failure to comply with the requirements for maintaining the operability of fire door, 02-BLD-STR-S71-18, 2H Emergency Diesel Gen Room Door SB Elev 271. The inspectors also identified an additional example of this violation which involved fire door, 01-BLD-STR-S07-3, Unit 1/Unit 2 Switchgear Door Service Building EL 307. The licensee entered the problems into their corrective action program as condition reports 417750 and 418705 for 02-BLD-STR-S71-18, and 430445, 01-BLD-STR-S07-3.

The inspectors identified a performance deficiency (PD) for the failure to maintain the fire doors operable per the requirements of the Fire Protection Program and consequently failing to declare the fire doors inoperable with appropriate compensatory measures. The PD was more than minor because it impacted the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and the related attribute of protection against external factors such as fire. This finding had a credible impact on safety because the inoperability of the fire doors would have an adverse impact on the functionality of the gaseous suppression systems. In accordance with NRC IMC 0609, Significant Determination Process, Appendix F, the inspectors performed a Phase 1 analysis and determined the finding resulted in very low significance, Green, because although the fire confinement program element was of high degradation, the fire frequencies related to the rooms were 1E-6 and the duration of the component inoperability was less than three days, which resulted in screening check frequency of 1E-8 which was less than the screening criteria of 1E-6. The cause of this finding involved the cross-cutting area of human performance, the component of resources, and the aspect of adequate equipment, H.2(d), because the licensee failed to ensure that fire door closures were adequate for the protection of equipment important to safety. (Section 1R05.2)

Green.

The inspectors identified a non-cited violation of North Anna Power Station,

Units 1 & 2 Renewed Facility Operating Licenses, NPF-4 & 7, Condition 2.D, Fire Protection, for failure to maintain in effect all provisions of their NRC-approved fire protection program. Specifically, the licensee failed to have adequate qualification testing results for installed aluminum conduits that penetrate fire barriers separating fire areas containing equipment required for safe shutdown. The requirement to have adequate qualification testing for such fire barrier penetrations is contained in Appendix A to Branch Technical Position APCSB 9.5-1, which is part of the licensees NRC-approved fire protection program. As part of the corrective actions, the licensee performed testing to determine the qualification of aluminum conduit penetrations, and performed modifications, as appropriate, to restore compliance.

The finding is more than minor because it is associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external factors (i.e.,

fire) and it affects the cornerstone objective of ensuring the reliability and capability of systems that respond to initiating events. Specifically, not having qualification testing results for aluminum conduits that penetrate fire rated barriers adversely affected the fire confinement capability defense-in-depth element, because subsequent testing revealed that some conduits did not meet the penetration seal criteria established in BTP APCSB 9.5-1. In accordance with NRC IMC 0609,

Significant Determination Process, Appendix F, the inspectors determined that the performance deficiency represented a finding of very low safety significance (Green).

Specifically, the fire barriers in question either provided a 2-hour or greater fire endurance rating, or the barriers separated rooms that did not contain equipment credited for fire safe shutdown of the plant. Inspectors determined that no cross cutting aspect was applicable to this performance deficiency because this finding was not indicative of current licensee performance. (Section 4OA5.4)

Green.

The inspectors identified a non-cited violation of 10 CFR 50, Appendix B,

Criterion XVI, Corrective Action, for the failure to identify a condition adverse to quality involving noncompliance with a licensee procedure during an apparent cause evaluation (ACE) for scaffolding adversely affecting the Unit 1 A charging pump.

The licensee entered this problem into their corrective action program as condition report 416488.

The inspectors determined that the failure to identify a condition adverse to quality involving noncompliance with a licensee procedure during an ACE was a performance deficiency (PD). The PD was more than minor because (1) if left uncorrected it would have the potential to result in a more significant safety event, and (2) it impacted the mitigating systems cornerstone objective to ensure the reliability and capability of systems which respond to initiating events and the related attribute of equipment performance because the reliability of the affected safety related components would be adversely impacted during a seismic event. In accordance with NRC Inspection Manual Chapter 0609, Significant Determination Process, the inspectors performed a Phase 1 analysis and determined the finding was of very low safety significance or Green because the affected equipment would not result in a total loss of a safety function during a seismic event. This finding involved the cross-cutting area of human performance, the component of the resources, and the aspect of procedure use and adherence, H.4(b), because the licensee failed to adequately follow procedures for the identification of seismic deficiencies involving scaffolding. (Section 4OA2.3)

Green.

The inspectors identified a non-cited violation of Technical Specification (TS)3.5.4, Refueling Water Storage Tank (RWST), for the failure to comply with the Limiting Conditions for Operation (LCO), while the Units 1 and 2 RWSTs were aligned to the non-seismic Refueling Purification (RP) system for purification during Mode 1, causing the RWSTs to be inoperable. Specifically, when the RP system was aligned to the RWST, the licensee did not declare the RWST inoperable. The licensee entered the problem into their corrective action program as condition report 397144 and suspended the use of procedures, 1-OP-16.4, Purification Operations of Unit 1 Storage Tank, and 2-OP-16.4, Purification Operations of Unit 2 Storage Tank, for purification of the RWST in Modes 1-4 until further review has been completed. The licensee had originally modified their procedures to allow this activity in 1996.

The failure to comply with the actions of TS LCO 3.5.4 while the Units 1 and 2 RWSTs were aligned to the non-seismic RP system for purification on September 4, 2010, and January 7, 2010, respectively, resulting in the inoperability of the RWSTs was a performance deficiency (PD). The PD was more than minor because it affected the design control attribute of the mitigating system cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. In accordance with NRC IMC 0609,

Significant Determination Process, the inspectors performed a Phase 1 analysis and determined that this finding was within the mitigating systems cornerstone and was potentially risk significant due to a seismic external event and therefore required a Phase 3 SDP analysis. A phase 3 risk assessment was performed by a regional SRA using the NRC SPAR model. A bounding one year exposure period was utilized. The non-seismic RP piping was assumed to fail at the same seismic input as that assumed for a loss of offsite power. The dominant sequence was a seismically induced non-recoverable loss of offsite power with a failure of the AFW system due to loss of the emergency condensate storage tank and failure of feed and bleed due to loss of the RWST leading to core damage. The risk was mitigated by the low probability of a seismic event and the use of a dedicated operator for isolation of the non-seismic piping. The analysis determined that the risk increase of the performance deficiency was an increase in core damage frequency less than 1E-6/year yielding a GREEN finding of very low safety significance. The finding had no cross-cutting aspects due to its legacy nature. (Section 1R18,2)

Licensee Identified Violations

A violation of very low safety significance was identified by the licensee and reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and its respective corrective actions are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

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

Unit 2 began the period at full RTP and operated at or near full power for the entire report period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection

.1 Seasonal Susceptibilities

a. Inspection Scope

The inspectors reviewed the licensees adverse weather preparations for hot weather operations, specified in 0-GOP-4.1, Hot Weather Operations, Revision 28, and the licensees corrective action program (CAP) database for hot weather related issues.

The inspectors walked down two risk-significant systems/areas listed below to verify compliance with the procedural requirements and to verify that the specified actions provided the necessary protection for the structures, systems, or components.

• Unit 1 & 2 auxiliary feedwater (AFW) pumps

• Unit 1 & 2 emergency diesel generators (EDG)

b. Findings

No findings were identified.

.2 Site Specific Event

a. Inspection Scope

The inspectors performed a site specific weather related inspection due to anticipated adverse weather conditions. On April 28, 2011, a tornado watch was issued for Louisa County. 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 were identified.

.3 Review of Offsite Power and Alternate AC Power Readiness

a. Inspection Scope

The inspectors verified that plant features, and procedures for operation and continued availability of offsite and alternative alternating current (AC) power systems were appropriate. The inspectors reviewed the licensees procedures affecting those areas, and the communications protocols between the transmission system operator and the nuclear power plant to verify that the appropriate information was exchanged when issues arose that could impact the offsite power system. The inspectors evaluated the readiness of the offsite and alternative AC power systems by reviewing the licensees procedures that address measures to monitor and maintain the availability and reliability of the offsite and alternative AC power systems.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial Walkdowns

a. Inspection Scope

The inspectors conducted four equipment alignment partial walkdowns to evaluate the operability of selected redundant trains or backup systems, listed below, with the other train or system inoperable or out of service. The inspectors reviewed the functional systems 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.

• Unit 1 '1J' EDG and support systems during planned maintenance on 1H EDG

• Unit 1 1B Quench Spray (QS) pump during planned maintenance on 1A QS pump

• Unit 1 'A' Motor Driven Auxiliary Feedwater (MDAFW) and Turbine Driven Auxiliary Feedwater (TDAFW) during planned maintenance on the B MDAFW

• Unit 1 B train casing cooling during planned maintenance on A train casing cooling system

b. Findings

No findings were identified.

.2 Complete Walkdown

a. Inspection Scope

The inspectors completed a detailed walkdown and inspection of the Unit 2 B Low Head Safety Injection (LHSI) outside containment to assess proper alignment and to identify discrepancies that could impact its availability and functional capacity. The inspectors assessed the physical condition and position of each accessible LHSI spray and casing cooling valve, whether manual, power operated or automatic to ensure correct positioning of the valves. The inspection also included a review of the alignment and the condition of support systems including fire protection, room ventilation, and emergency lighting. Equipment deficiency tags were reviewed and the condition of the system was discussed with the engineering personnel. Documents reviewed are listed in the Attachment to this report.

b. Findings

A portion of this inspection was performed during the first quarter and a related finding, NCV 05000339/2011002-01, Inadequate Installation of Unit 2 Low Head Safety Injection Piping and Related Supports, was discussed in North Anna Power Station -

NRC Integrated Inspection Report 05000338/2011002 and 05000339/2011002.

1R05 Fire Protection

a. Inspection Scope

The inspectors conducted focus tours of the six areas listed below that are important to reactor safety to verify the licensees implementation of fire protection requirements as described in fleet procedures CM-AA-FPA-100, Revision 3, Fire Protection/Appendix R (Fire Safe Shutdown) Program, CM-AA-FPA-101, Control of Combustible and Flammable Materials, Revision 3, and CM-AA-FPA-102, Fire Protection and Fire Safe Shutdown Review and Preparation Process and Design Change Process, Revision 2.

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. The inspectors also maintain sensitivity of fire protection aspects during plant status tours of general plant areas.

• Fuel Oil Pump House Room A and B 1 (fire zones 10Aa / FOPR-A and 10Ba /

FOPR-B), Motor Control Center Room (fire zone B10C/ MCC), and Casing Cooling Tank & Pump House Unit 1 (fire zone Z-41-1 / CCT&PH-1) and Unit 2 (fire zone Z-41-2 / CCT&PH-2)

• Charging Pump Cubicles 1-1A (fire zone 11Aa / CPC-1A), 1-1B (fire zone 11Ba /

CPC-1B), 1-1C (fire zone 11Ca / CPC-1C), 2-1A (fire zone 11Da / CPC-2A), 2-1B (fire zone 11Ea / CPC-2B), and 2-1C (fire zone 11Fa / CPC-2C)

• Cable Vault and Tunnel Unit 2 (includes Control Rod Drive Room and Z-27-2)(fire zone 3A-2a / CV & T-2)

• Cable Tray Spreading Room Unit 1 (fire zone 4-1b / CSR-1) and Cable Tray Spreading Room Unit 2 (fire zone 4-2B / CSR-2)

• TDAFW Pump Room Unit 1 (fire zone 14A-1a / TDAFW-1), TDAFW Pump Room Unit 2 (fire zone 14A-2 / TDAFW-2), MDAFW Pump Room Unit 1 (fire zone 14B-1a /

MDAFW-1), and MDAFW Pump Room Unit 2 (fire zone 14B-2a / MDAFW-2)

• Main and Station Service Transformers (fire zone Z-8C / XFMRS), Security Auxiliary Power Supply Building (fire zone Z-39 / APSB), and Alternate AC Building (fire zone Z-52 / AAC)

.1 Failure to Control Transient Fire Loads in a Safety-Related Area

Introduction:

The inspectors identified a non-cited violation of the North Anna Power Station, Unit 1 Renewed Facility Operating License, NPF-4, Condition 2.D, Fire Protection, which involved a failure to comply with transient fire load procedure requirements that resulted in transient fire loads improperly placed in a safety-related area, Unit 1 MDAFW room, contrary to transient fire load report requirements.

Description:

On April 19, 2011, the inspectors identified transient fire loads or combustibles consisting of combustible Class B liquids, and Class A miscellaneous fire loads, located in a safety-related area, the Unit 1 MDAFW room. The inspectors noted that procedure CM-AA-FPA-100, Fire Protection Program, Revision 3, step 3.4.1 states, Use and store combustible materials, including flammable and combustible liquids and aerosols, fuel gases, oxygen, Dry Ion Exchange Resin, HEPA filters, and Charcoal Filters, in accordance with the requirements found in CM-AA-FPA-101, Control of Combustible and Flammable Materials. The inspectors identified the following deficiencies associated with the requirements of the transient fire load report (TFLR) as required by procedure CM-AA-FPA-101, Control of Combustible and Flammable Materials, Revision 3, Attachment 2, North Anna Power Station and Surry Power Station Program Requirements, Section 3.2, Transient Combustibles:

• The TFLR was not posted in the area containing the transient fire loads as required by step 3.2.a.6.

• The quantity of Class B liquids, approximately 63 gallons of new and used oil, exceeded the limit, 60 gallons, established by the TFLR and the restriction for the Unit 1 MDAFW room listed in Attachment 8 of CM-AA-FPA-101.

• Class A combustibles consisting of an extension cord, Tygon tubing, cardboard, oily rags which were in an unapproved container, and portable pump were not identified on the TFLR.

• The Class B liquids, 55 gallons of new oil in a drum and approximately 8 gallons of waste oil in a 55 gallon drum were place in a position exceeding the 1 foot separation limit for safety-related equipment established by the TFLR thereby exposing the emergency condensate storage tank level transmitter.

The inspectors concluded that the licensee failed to meet the fire protection program requirements relative to the control of transient fire loads.

Analysis:

The inspectors identified a performance deficiency (PD) associated with the failure to control transient fire loads as noted above and contrary to the requirements of procedure CM-AA-FPA-101. The PD was more than minor and therefore a finding, because it impacted the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and the related attribute of protection against external factors such as fire. This finding had a credible impact on safety because the transient fire load exceeded the limit of Class B liquid transient loads. In accordance with NRC IMC 0609, Significant Determination Process, Appendix F, the inspectors performed a Phase 1 analysis and determined that the finding was of very low safety significance or Green because although the combustible controls program element was of high degradation due to oily rags in an unapproved container, the Unit 1 MDAFW room had a low fire frequency of 1E-6 and the duration of the violation was less than 3 days, which resulted in a screening check frequency of 1E-8 which was less than the screening criteria of 1E-6. The cause of this finding involved the cross-cutting area of human performance, the component of work practices, and the aspect of procedural compliance, H.4(b), because the licensee failed to follow procedural requirements for the control of transient fire loads in a safety-related area.

Enforcement:

North Anna Power Station, Unit 1 Renewed Facility Operating License, NPF-4, Condition 2.D., Fire Protection, states in part that VEPCO shall implement and maintain in effect all provisions of the approved fire protection program as described in the UFSAR and as approved in the Safety Evaluation Report dated February, 1979. The UFSAR, Section 9.5.1.1, Design Bases, identifies one requirement as the Stations Fire Protection Program document which is procedure CM-AA-FPA-100 of which Section 6.1.3b, Transient Combustibles, states: Transient fire loads may be located in safety related areas only if written authorization is obtained from Supervisor Nuclear Site Safety and the material shall be removed immediately upon completion of the work. Contrary to the above, the licensee located transient fire loads in the safety-related area, Unit 1 MDAFW Room, on April 19, 2011, which exceeded and/or was not identified on the written authorization. Because the finding is of very low safety significance and because it has been entered into the licensees CAP as CR423054, this violation is being treated as a Green NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000338/2011003-01, Failure to Control Transient Fire Loads in a Safety-Related Area.

.2 Inadequate Fire Protection Program Implementation Results in Inoperability of Fire

Doors

Introduction:

The inspectors identified a non-cited violation of the North Anna Power Station, Units 1 & 2 Renewed Facility Operating Licenses, NPF-4 & 7, Condition 2.D, Fire Protection, which involved a failure to comply with the requirements for maintaining the operability of fire door, 02-BLD-STR-S71-18, 2H Emergency Diesel Gen Room Door SB Elev 271. The inspectors also identified an additional example of this violation which involved fire door, 01-BLD-STR-S07-3, Unit 1/Unit 2 Switchgear Door Service Building EL 307.

Description:

On March 14, 2011, the inspectors identified that fire door, 02-BLD-STR-S71-18, 2H EDG north door, would not self-close. Subsequently, the inspector noted the following control room log entries:

• 3/14, 1630: Ventilation has been properly adjusted to allow for proper closure of all fire doors.

• 3/14, 1631: Additional exhaust fans were secured due [to] wind coming from the south and 2H EDG room door not closing correctly.

The inspectors determined that

(1) the licensee did not declare the fire door inoperable, and

(2) licensee administrative procedure, CM-AA-FPA-100, Fire Protection Program, Revision 2, did not allow for the use of ventilation alignments to ensure the doors were self-closing. While the licensee had initially entered the issue in the CAP as CR417750, they subsequently initiated CR418705 on March 22, 2011, to address these concerns.

On June 6, 2011, the inspectors identified the following Unit 1 control room log entry time stamped 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> for activities occurring during the nightshift, Tagged 1-HV-F-18 (307 SWGR exhaust fan) due to broken belts. CR submitted. Secured 1-HV-F-17 also to allow fire door between SWGRs to close properly. The inspectors noted that the above mentioned door is identified as 01-BLD-STR-S07-3, Unit 1/Unit 2 Switchgear Door Service Building EL 307. The inspectors also noted that the licensee had not declared the fire door inoperable but, rather, manipulated ventilation systems to allow the door to self-close. When challenged by the inspectors on their conclusion, the licensee initiated CR430445.

The inspectors reviewed the response section of corrective action (CA) 195429, OPS to evaluate NRC question regarding dire door operability/functionality, and noted the following statement, Operations department has never questioned the non-functionality of a fire door when it would not close and latch without assistance. But Operations has had a long standing philosophy that if ventilation could be adjusted to allow for auto closure and latching of the door that log entries documenting the issue were not required. The inspectors reviewed CM-AA-FPA-100, Revision 2 and Revision 3 which was effective on March 23, 2011, and noted that Attachment 2, step 3.1.2.n.4 stated, Fire Doors shall be self closing or provided with approved closing mechanisms. The inspectors noted that CM-AA-FPA-100 has no provisions for using ventilation changes to ensure a fire door is self-closing, and that using this process can mask problems with door closure mechanism. The inspectors also noted that the EDG rooms and normal switchgear rooms are protected by carbon dioxide, a gaseous suppression system, which requires closure of the openings in the fire barriers. Consequently, a fire door which will not self-close presents an opening in the wall or fire barrier for the respective room. Based on the aforementioned information, the inspectors concluded that the licensee had failed to meet the requirements specified in CM-AA-FPA-100 for fire door operability.

Analysis:

The inspectors identified a PD for the failure to maintain the fire doors operable per the requirements of the Fire Protection Program. Consequently, the licensee failed to declare the fire doors inoperable and did not take appropriate compensatory measures. The PD was more than minor and therefore a finding, because it impacted the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and the related attribute of protection against external factors such as fire. This finding had a credible impact on safety because the inoperability of the fire doors would have an adverse impact on the functionality of the gaseous suppression systems. In accordance with NRC IMC 0609, Significant Determination Process, Appendix F, the inspectors performed a Phase 1 analysis and determined the finding resulted in very low significance, Green, because although the fire confinement program element was of high degradation, the fire frequencies related to the rooms were 1E-6 and the duration of the component inoperability was less than three days, which resulted in screening check frequency of 1E-8 which was less than the screening criteria of 1E-6. The cause of this finding involved the cross-cutting area of human performance, the component of resources, and the aspect of adequate equipment, H.2(d), because the licensee failed to ensure that fire door closures were adequate for the protection of equipment important to safety.

Enforcement:

North Anna Power Station, Units 1 & 2 Renewed Facility Operating Licenses, NPF-4 & 7, Condition 2.D., Fire Protection, states in part that VEPCO shall implement and maintain in effect all provisions of the approved fire protection program as described in the UFSAR and as approved in the SER dated February, 1979. The UFSAR, Section 9.5.1.1, Design Bases, identifies one requirement as the Stations Fire Protection Program document which is procedure CM-AA-FPA-100 of which Attachment 2, step 3.1.2.n.4 states in part that fire doors shall be self-closing. Contrary to this, on March 14, 2011, and June 6, 2011, the licensee failed to ensure that fire doors 02-BLD-STR-S71-18 and 01-BLD-STR-S07-3, respectfully, were self-closing and did not declare the doors inoperable. Because the finding is of very low safety significance and because it has been entered into the licensees CAP as CR417750, CR418705, and, CR430445 this violation is being treated as a Green NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000338, 339/2011003-02, Failure to Maintain Fire Doors in Accordance With the Fire Protection Program.

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors assessed the internal flooding vulnerability of the Unit 1 and 2 air conditioning chiller rooms with respect to adjacent safety-related and non-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 other passive flood protection features for equipment protection as well as their overall material condition.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

a. Inspection Scope

The inspectors observed an operator requalification simulator exam scenario which involved a loss of instrument air in containment, a reactor coolant system (RCS) leak in containment, a loss of bearing cooling water to secondary systems, a small break loss of coolant accident (SBLOCA), a failure of the high head charging pumps to automatically start, and a failure of the solid state protection system Phase A isolation signal.

The inspectors observed crew performance in terms of communications; ability to prioritize failures in order 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 manager, including the ability to identify and implement appropriate TS actions and, when required, emergency action levels as the Site Emergency Manager. The inspectors observed the post training critique to determine that weaknesses or improvement areas revealed by the training were captured by the instructor, reviewed with the operators, and appropriate actions initiated.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the equipment issue for CR418535, 2J EDG has exceeded the MRule unavailability, and evaluated the effectiveness of the respective licensee's preventive and corrective maintenance. The inspectors performed a walkdown of the accessible portions of the system, performed an in-office review of procedures and evaluations, and held discussions with licensee staff. The inspectors compared the licensees actions with the requirements of the Maintenance Rule (10 CFR 50.65), and licensee procedure ER-AA-MRL-10, Maintenance Rule Program, Revision 4.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors evaluated, as appropriate, the six 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 in compliance 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.

• Unplanned inoperability of A Reserve Station Service Transformer (RSST) and related TS offsite power source for the 1J 4160V emergency bus

• 0-AP-41, Severe Weather, Revision 52, entered for a tornado watch issued for Louisa County on April 5, 2011

• Emergent repairs for inoperability of 2J EDG due to severe load swings

• C RSST tap changer replacement

• Emergent entry into an Orange risk condition due to inoperability of the top changer for B RSST

• Failure of Station Blackout Diesel generator performance test

b. Findings

No findings were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed seven operability evaluations, listed below, affecting risk-significant mitigating systems, 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 Significant Determination Process (SDP). The inspectors review included a verification that operability determinations (OD) were made as specified by procedure OP-AA-102, Operability Determination, Revision 6.

• OD000408, "OD required to document acceptability of 2-EI-CB-48B door, for seismic condition adverse to quality identified by the inspectors

• OD000410, Evaluate heat at the time of NUHOMS DSCS loading as described in CR419242

• OD000411, Ops requests OD to establish operability of C RSST with suspect Tap Changer

• CR422008, Common cause failure evaluation required due to 2J EDG erratic generator output

• CR423054, Two oil drums staged in U1 AFW MDPH discovered with no transient loading sheet

• OD000418, 2-FW-134 C Steam Generator AFW check valve is experiencing back leakage

• CR429231, 2-SW-REJ-18C found with bolt protruding into expansion joint

b. Findings

Corrective action aspects relating to OD000408 are discussed in section 4OA2.2 of this report. The enforcement aspects for CR423054 and OD000410 are discussed in sections 1R05 and 4OA7 of this report, respectfully.

1R18 Plant Modifications

.1 Temporary Modifications

a. Inspection Scope

The inspectors reviewed a procedure controlled temporary modification per 1-OP-26.1, Transferring 4160-Volt Busses, Revision 29, to verify that the modification did not affect systems operability or availability as described by the TS and UFSAR. In addition, the inspectors verified that the temporary modification was in accordance with VPAP-1403, Temporary Modifications, Revision 13, and the related work package, that adequate controls were in place, procedures and drawings were updated, and post-installation tests verified the operability of the affected systems.

b. Findings

No findings were identified.

.2 Permanent Modifications

a. Inspection Scope

The inspectors reviewed 1-OP-16.4, Purification Operations of Unit 1 Storage Tank, Revision 28, and 2-OP-16.4, Purification Operations of Unit 2 Storage Tank, Revision 23, for purification of the RWST to verify that the permanent procedure modification did not affect systems operability or availability as described by the TS and UFSAR. In addition the inspectors reviewed the 10 CFR 50.59 change package and the safety evaluation that allowed manual action/compensatory measures to cross connect the RWST to the Refueling Purification System in Modes 1-4.

b. Findings

Introduction:

The inspectors identified a Green NCV of TS 3.5.4, Refueling Water Storage Tank (RWST), for the failure to comply with the Limiting Conditions for Operation (LCO), while the Units 1 and 2 RWSTs were aligned to the non-seismic RP system for purification in Mode 1, resulting in the inoperability of the RWSTs.

Description:

In 1996, the licensee revised 1-OP-16.4, Purification Operations of Unit 1 Storage Tank, and 2-OP-16.4, Purification Operations of Unit 2 Storage Tank, to permit purification of the RWST in Modes 1-4 with contingency actions in place. The procedure allowed purification of the RWST without declaring the RWST inoperable nor entering the TS action statement. The change relied on manual operator actions as compensatory actions to close the valve and maintain the RWST operable. The Refueling Purification (RP) system is a non-safety, non-seismic system and is separated from the RWST by a normally closed safety-related boundary valve. The RWST is seismically qualified and a safety-related system described in TS 3.5.4. The Unit 1 RWST can be mechanically cross connected to the RP system, via 1-RP-11 (Unit 1 RWST to RP Pumps Suction Header Isolation Valve). The Unit 2 RWST can be mechanically cross connected to the RP system, via 1-RP-53 (Unit 2 RWST to RP Pumps Suction Header Isolation Valve). Both 1-RP-11 and 1-RP-53 are manually operated valves and have no automatic isolation signals. In September 2010 the Resident Inspectors determined this practice was not consistent with the TS requirements. In response, the licensee entered the issue into their CAP as CR397144 and placed the respective procedures on administrative hold until further evaluations were performed.

Analysis:

The inspectors identified a PD which was the failure to comply with the actions of TS LCO 3.5.4 while the Units 1 and 2 RWSTs were aligned to the non-seismic RP system for purification on September 4, 2010, and January 7, 2010, respectively, resulting in the inoperability of the RWSTs. The PD was more than minor because it affected the design control attribute of the mitigating system cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. In accordance with NRC IMC 0609, Significant Determination Process, the inspectors performed a Phase 1 analysis and determined that this finding was within the mitigating systems cornerstone and was potentially risk significant due to a seismic external event and therefore required a Phase 3 SDP analysis. A phase 3 risk assessment was performed by a regional SRA using the NRC SPAR model. A bounding one year exposure period was utilized. The non-seismic RP piping was assumed to fail at the same seismic input as that assumed for a loss of offsite power. The dominant sequence was a seismically induced non-recoverable loss of offsite power with a failure of the AFW system due to loss of the emergency condensate storage tank and failure of feed and bleed due to loss of the RWST leading to core damage. The risk was mitigated by the low probability of a seismic event and the use of a dedicated operator for isolation of the non-seismic piping. The analysis determined that the risk increase of the performance deficiency was an increase in core damage frequency less than 1E-6/year yielding a GREEN finding of very low safety significance. The finding had no cross-cutting aspects due to its legacy nature.

Enforcement:

TS LCO 3.5.4, Condition B., requires that when the RWST is inoperable in Modes 1-4 for reasons other than boron concentration not within limits or temperature not within limits, restore the RWST to operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and be in Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Contrary to the above requirement, purification of the Unit 1 RWST, while online in Mode 1, occurred for approximately 68 hours7.87037e-4 days <br />0.0189 hours <br />1.124339e-4 weeks <br />2.5874e-5 months <br /> in September 2010, without declaring the RWST inoperable. In addition, purification of the Unit 2 RWST, while online in Mode 1, occurred for approximately 12 days in January 2010 without declaring the RWST inoperable. The licensee suspended 1-OP-16.4 and 2-OP-16.4 to remove the capability to purify the RWST in Modes 1-4.

Because the finding is of very low significance and has been entered into their CAP as CR397144, this violation is being treated as a Green NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000338, 339/2011003-03, Failure to Comply with Technical Specifications for Alignment of the Refueling Water Storage Tank to the Non-Seismic Refueling Purification System.

1R19 Post Maintenance Testing

a. Inspection Scope

The inspectors reviewed five post maintenance test procedures and/or test activities for selected risk-significant mitigating systems listed below, 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) tests 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 VPAP-2003, Post Maintenance Testing Program, Revision 13.

• WO 59102289381, Replace 02-EG-3A-2EGSJ10-Relay for 2J EDG

• WO 59101656835, Calibrate temperature switch 01-EG-TS-618H-IBISSW for Unit 1 1H EDG

• WO 59102245493, Replace emergency condensate storage tank sample isolation valve 1-FW-540

• WO 59101658984, Remove, Test, and replace relief valve 1-CC-119

• WO 59102310839, Repair 2J EDG frequency out of specification

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

For the five surveillance tests listed below, the inspectors examined the test procedures, witnessed testing, or 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.

In-Service Tests:

• 1-PT-74.2B.2, Component Cooling Pump 1-CC-P-1B Biennial 1st Comprehensive Pump Test, Revision 2

• 1-PT-63.1B, Quench Spray System - B Subsystem, Revision 38

• 1-PT-57.1B, Emergency Core Cooling Subsystem - Low Head Safety Injection Pump (1-SI-P-1B), Revision 53 Other Surveillance Tests:

• 2-PT-82.4B, 2J Diesel Generator Test (Start by ESF Actuation), Revision 64-P2-OT01

• 1-PT-82J, 1J Emergency Diesel Generator Slow Start Test, Revision 45

b. Findings

No findings were identified.

1EP6 Drill Evaluation

a. Inspection Scope

On April 5, 2011, the inspectors reviewed and observed the performance of an emergency planning full participation drill that involved a tornado and associated damage to the safety related components, a rod control failure, a SBLOCA, loose parts within the reactor vessel, leakage increasing to a large break loss of coolant accident, loss of the quench spray pumps, loss of multiple recirculation spray pumps, and a containment penetration weld leak resulting in an Alert and subsequent escalation to a Site Area Emergency followed by a 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 and are noted in the Attachment to this report.

b. Findings

No findings were identified.

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

The inspectors performed a periodic review of the two following Unit 1 and 2 PIs to assess the accuracy and completeness of the submitted data and whether the performance indicators were calculated in accordance with the guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspection was conducted in accordance with NRC inspection procedure 71151, Performance Indicator Verification. Specifically, the inspectors reviewed the Unit 1 and Unit 2 data reported to the NRC for the period April 1, 2010, through March 31, 2011.

Documents reviewed included applicable NRC inspection reports, licensee event reports, operator logs, station performance indicators, and related condition reports (CRs).

• RCS Specific Activity

• Reactor Coolant System Leakage

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

.1 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 CAP. This review was accomplished by reviewing daily CR report summaries and periodically attending daily CR Review Team meetings.

.2 Annual Sample: Review of CR417303 and CR418074

a. Inspection Scope

The inspectors performed a review regarding the licensees assessments and corrective actions for CR417303, NRC Resident Inspector identified issue with door latch on 2-EI-CB-48B, and CR418074, 2-EI-CB-48B door latch issue, to ensure that the full extent of the issue was identified, an appropriate evaluation was performed, and appropriate corrective actions were specified and prioritized. The inspectors also evaluated the CRs against the requirements of the licensees CAP as specified in procedure, PI-AA-200, Corrective Action Program, Revision 17 and 10 CFR 50, Appendix B. Documents reviewed are listed in the Attachment to this report.

b. Findings and Observations

No findings of significance were identified. On March 12, 2011, during a plant status tour on Unit 2 the inspectors identified an open cabinet door with missing latching rods on 02-EI-CB-48B, Auxiliary Relay Rack No 2 Cabinet, which is a safety-related cabinet containing relays impacting reactor coolant system pressurizer heaters, steam dump controls, boric acid pumps, alarms for nuclear instrumentation and the C accumulator discharge valve. In response, the licensee entered the problem into their CAP as CR417303. Additionally, when challenged by inspectors regarding the operability review, the licensee initiated CR418074 to perform a formal operability determination as required by licensee procedure, OP-AA-102, Operability Determination, Revision 6, since the problem for the safety-related component involved at least a non-conforming condition which was not identified in the licensees initial engineering evaluation. The licensee completed OD000408 on March 24, 2011, and determined the cabinet was operable but degraded and non-conforming relative to seismic events.

On April 14, 2011, the inspectors performed a corrective action review of CR417303 and noted that the licensee had written the problem as door appears ajar but was found latched. The inspectors had taken photographic evidence of the problem showing a clearly open door when initially identified and challenged the licensee on the accuracy of their problem description. The licensee subsequently reopened CR417303 to correct the problem description and attached the pictures for the historical record. The inspectors also reviewed the work order for correction of the problem involving missing latching rods and noted that this was initially identified by NRC inspectors on September 13, 2006, and documented in CR001299. The inspectors noted that WO59075675501 was not complete and had a scheduled start date of February 7, 2012. The inspectors questioned the licensee on the length of time of approximately 4.5 years required to correct a safety-related component which was operable but non-conforming and degraded. The licensee revised their start date to August 10, 2011, and is waiting on parts to correct the problem. Additionally, the licensee initiated CR422342, Clarification needed for the terms degraded and non-conforming for ODs, for appropriate revisions to OP-AA-102. The inspectors continue to monitor the licensees CAP for correct application of their Operability Determination program and sensitivity to safety-related components with seismic related deficiencies.

.3 Annual Sample: Review of CR407206, Unanalyzed Scaffolding in 1-CH-P-1A

a. Inspection Scope

The inspectors performed a review regarding the licensees assessments and corrective actions for CR407206, Unanalyzed scaffolding in 1-CH-P-1A, to ensure that the full extent of the issues were identified, an appropriate evaluation was performed, and appropriate corrective actions were specified and prioritized. The inspectors also evaluated the CR against the requirements of the licensees CAP as specified in procedure, PI-AA-200, Corrective Action Program, Revision 17, and 10 CFR 50, Appendix B.

b. Findings and Observations

Introduction:

The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the failure to identify a condition adverse to quality involving noncompliance with a licensee procedure during an apparent cause evaluation (ACE) for scaffolding adversely affecting the Unit 1 A charging pump. The licensee entered this problem into their corrective action program as CR416488.

Description:

On December 12, 2010, with Unit 1 operating in Mode 1 at 100% power, the licensee determined that the A charging pump was inoperable due to the installation of scaffolding which did not have the engineering reviews for high risk or seismic conditions. The licensee entered this problem in their CAP as CR407206 and subsequently submitted Licensee Event Report (LER) 05000338/2010-005, Unanalyzed Scaffolding Renders Charging pump Inoperable Due to Human Error, which is discussed in section 4OA3.1 of this report.

On completion, the inspectors reviewed ACE018483, and noted that the cause involved human performance errors within the licensees Nuclear Station Services group.

However, the inspectors determined that the ACE did not identify another significant cause which involved licensee procedure OP-AA-100, Conduct of Operations, Revision 10. Specifically, Attachment 5, Facilities and Equipment, the standards for operations personnel state, Operators are advocates for improvement and lead the site in enforcing high standards with respect to housekeeping, material conditions, and equipment storage. Examples include, in part:

• Scaffolding certification is properly posted

• Seismic housekeeping is maintained Additionally, Attachment 5 states, Working closely with others, Operators make sure that housekeeping issues are resolved in a timely manner. The inspectors determined that operators performing rounds in the areas involving the above scaffolding failed to comply with the licensee standards because they failed to ensure the certification was posted properly and that seismic housekeeping was not maintained since the scaffolding as erected was not allowed within the room for the current plant operating mode. The inspectors also determined that the associated ACE should have identified the noncompliance with OP-AA-100 as another barrier to the scaffolding event. The inspectors concluded that the failure to identify the noncompliance with OP-AA-100 was contrary to the requirements of 10 CFR 50, Appendix B, Criterion XVI, because the deficiency or procedure adherence inadequacy involved a safety-related component. In response, the licensee initiated CR416488 for appropriate corrective action regarding the implementation of ACEs.

Analysis:

The inspectors determined that the failure to identify a condition adverse to quality involving noncompliance with a licensee procedure during an apparent cause evaluation for the aforementioned scaffold event was a PD. The PD was more than minor and therefore a finding, because

(1) if left uncorrected it would have the potential to result in a more significant safety event, and

(2) it impacted the mitigating systems cornerstone objective to ensure the reliability and capability of systems which respond to initiating events and the related attribute of equipment performance because the reliability of the affected safety related components would be adversely impacted during a seismic event. In accordance with NRC IMC 0609, Significant Determination Process, the inspectors performed a phase 1 analysis and determined the finding was of very low safety significance or Green because the affected equipment would not result in a total loss of a safety function during a seismic event. This finding involved the cross-cutting area of human performance, the component of the resources, and the aspect of procedure use and adherence, H.4(b), because the licensee failed to adequately follow procedures during the identification of related apparent causes of the event.

Enforcement:

10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," states in part that measures shall be established to assure that conditions adverse to quality are promptly identified. Contrary to the above, on December 12, 2010, the licensee failed to promptly identify a condition adverse to quality involving noncompliance with a licensee procedure during an apparent cause evaluation for scaffolding adversely affecting the A charging pump. Because the finding is of very low safety significance and it was entered into the licensees CAP as CR416488, this violation is being treated as a Green NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000338/2011003-04, Inadequate Cause Evaluation for Scaffolding Affecting the Unit 1 A Charging Pump.

.4 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensees CAP documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment and corrective maintenance issues but also considered the results of daily inspector corrective action program item screening discussed in Section 4OA2.1. The review included issues documented outside the normal correction action program in system health reports, corrective maintenance work orders, component status reports, site monthly meeting reports, and maintenance rule assessments. The inspectors review nominally considered the six month period of January, 2011 through June, 2011 although some examples expanded beyond those dates when the scope of the trend warranted. The inspectors compared and contrasted their results with the results contained in the licensees latest integrated quarterly assessment report. Corrective actions associated with a sample of the issues identified in the licensees trend report were reviewed for adequacy.

b. Assessment and Observations No findings of significance were identified. In general, the licensee has identified trends and has addressed the trends with their corrective action program. However, the inspectors noted additional problems identified during extent of condition inspections for safety-related pipe support issues from a previous NRC identified problem as noted in section 1R04 of this report. Specifically, the inspectors identified the following CRs:

• CR427815, U-2 SI pipe support not in contact with pipe 8 in. SI-449-153A-Q2

• CR427850, As-built U2 SI piping - support does not match design documentation

• CR428288, U-1 SI pipe support not in contact with pipe 8 in. SI-49-153A-Q2

• CR429135, U-1 SI pipe supports not in contact with pipe 8 in. SI-40-153A-Q2 The inspectors continue to monitor the licensees corrective action progress regarding the safety-related pipe support problems.

4OA3 Event Followup

.1 (Closed) Licensee Event Report (LER) 05000338/2010-005-00: Unanalyzed Scaffolding

Renders Charging Pump Inoperable Due to Human Error On December 12, 2010, with Unit 1 operating in Mode 1 at 100% power, the licensee determined that the A charging pump was inoperable due to the installation of scaffolding which did not have the engineering reviews for high risk or seismic conditions. One cause of the event was human error which led to the incorrect status in the scaffold tracking program indicating the scaffold had been removed prior to declaring the pump operable from previous maintenance. The licensee entered this problem in their CAP as CR407206. The enforcement aspects are discussed in section 4OA2.3 of this report. This LER is closed.

.2 (Closed) LER 05000338/2011-001-00: Annunciator Card Failure Due To Carbon

Resistor Degradation

a. Inspection Scope

On February 3, 2011, the control room operators received annunciator, 1H-G4, Annunciator System DC Ground, and subsequently noticed a strong, acrid smell within the control room area. An investigation revealed flames approximately 2 - 4 inches in height coming from a circuit card in the Hathaway annunciator cabinet, 1-EI-CB-21. The fire was extinguished and the problem entered into their CAP as CR412487. This LER is closed.

b. Findings

Introduction:

A self-revealing finding was identified regarding inadequate corrective action associated with control room annunciator card resistor failures resulting in a fire in the respective cabinet located in the Units 1 and 2 control room complex. The significance of this finding is to be determined (TBD) pending completion of a significance evaluation.

Description:

On February 3, 2011, the control room operators received annunciator, 1H-G4, Annunciator System DC Ground, and subsequently noticed a strong, acrid smell within the control room area. An investigation revealed flames approximately 2 - 4 inches in height coming from a circuit card in the Hathaway annunciator cabinet, 1-EI-CB-21. The fire was extinguished and the problem entered into their CAP as CR412487. The inspectors reviewed the corrective action history related to annunciator card failures and noted the following timeline:

• January 20, 2010: the licensee initiated CR365779, Annunciator did not illuminate during performance of 2-PT-32.1.5, for which apparent cause evaluation (ACE)18031 was completed on March 11, 2010, but did not specifically note that the resistor failure was a fire precursor.

• June 27, 2010: CR385982 was initiated for an annunciator problem and a slight acrid smell in the control room. CA172487 was initiated for maintenance inspections that identified degraded resistors on annunciator cards causing enough heat to melt an adjacent plastic relay.

• June 30, 2010: CR386430, Annunciator card in 1-EI-CB-12 found to be severely overheated, was initiated as a result of the inspections completed for CA172487, and CA172718, document completion of inspection, results, and any additional recommendations, was also initiated.

• July 7, 2010: CR387108, Several backboards V & W Annunciators cards had overheated resistors and relays, was initiated based on the inspections performed by CA172718. This CR also initiated CA173282, investigate annunciator card issues and document long-term corrective actions, and CA173407, Due 7-15, CAART update, CA to Engineering to assess immediate threat.

• July 14, 2010: CA173407 stated, The annunciator cards for 1-EI-CB-12 & 13 have all been inspected by I&C with the above listed items requiring replacement/repair as a proactive measure due to the obvious degradation. The condition of the associated resistors/relays does not warrant an immediate threat concern, but the identified components should be replaced/repaired as soon as practicable.

• July 28, 2010: CA174851, Replace all carbon resistors in the Hathaway system, was initiated with a due date of April 13, 2011.

• October 24, 2010: CR400369, The input resistor and relay for annunciator 2B-H1 need to be replaced, was initiated and stated, Operations noticed a burnt smell in Unit 2 control room and the annunciator for PRZ RELIEF TK HI TEMP, 2B-H1, locked in. This CR was closed to WO59102227590 which documented, Found the resistor & relay badly burned.

The inspectors reviewed ACE18534 initiated from CR412487 and noted that the licensee concluded the cause was a lack of prioritization of the work order associated with the replacement of the resistors in the Hathaway system. The inspectors reviewed the licensees CAP procedure, PI-AA-200, Corrective Action, and noted the following steps:

• Step 5.3.7 Condition Adverse to Quality, An all-inclusive term used in reference to any of the following: failures, malfunctions, deficiencies, deviations, defective material and equipment and non-conformances. These conditions are required to be promptly identified and corrected.

• Step 5.3.13 Deviating Condition, An other-than-expected result of an activity, or a non-routine occurrence or condition, regardless of quality classification, that affects or results in the following: Defective or malfunctioning equipment.

The inspectors concluded that the licensee failed to meet the standards established by their CAP procedure for adequate corrective action for a deviating condition or condition adverse to quality (CAQ) associated with annunciator card resistor degradation which subsequently resulted in a fire in the Units 1 and 2 control room complex. The inspectors also noted that the licensee failed to understand the significance of the resistor degradation with respect to possible fire and resultant impact on a common control room for both units.

Analysis:

A self-revealing PD was identified for the failure to take adequate corrective action for degradation of annunciator card resistors in accordance with the standards as established by the licensees corrective action program procedure, PI-AA-200 which resulted in a fire in the respective annunciator cabinet located in the Units 1 and 2 control room complex. The PD was more than minor and therefore a finding, because it could be reasonably viewed as a precursor to a significant event based on fire development leading to an evacuation of the control room. In accordance with NRC IMC 0609, Significant Determination Process, and the associated Appendix F, the inspectors performed a Phase 1 analysis and determined the finding would require a Phase 2 analysis be a regional senior reactor analyst because the fire impacts the control room. Consequently, the significance of this finding is TBD pending completion of the significance evaluation. The cause of this finding involved the cross-cutting area of problem identification and resolution, the component of the corrective action program, and the aspect of appropriate and timely corrective action, P.1(d), because the licensees corrective action plan, in spite of the additional failures involving fire precursors, was not timely to preclude a fire event.

Enforcement:

Licensee procedure, PI-AA-200, requires that a CAQ is required to be promptly identified and corrected. Contrary to this, on February 3, 2011, the licensee failed to adequately correct a CAQ involving degradation of annunciator card resistors which resulted in a fire in the Units 1 and 2 control room complex. Pending determination of safety significance, this finding is identified as a FIN-TBD, 05000338, 339/2011003-05, Failure to Take Adequate Corrective Action to Preclude a Fire in the Units 1 and 2 Control Room Complex.

4OA5 Other Activities

.1 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 were identified.

.2 (Closed) NRC Temporary Instruction 2515/183, Followup to the Fukushima Daiichi

Nuclear Station Fuel Damage Event

a. Inspection Scope

The inspectors assessed the activities and actions taken by the licensee to assess its readiness to respond to an event similar to the Fukushima Daiichi nuclear plant fuel damage event. This included:

(1) an assessment of the licensees capability to mitigate conditions that may result from beyond design basis events, with a particular emphasis on strategies related to the spent fuel pool, as required by NRC Security Order Section B.5.b issued February 25, 2002, as committed to in severe accident management guidelines, and as required by 10 CFR 50.54(hh);

(2) an assessment of the licensees capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63 and station design bases;

(3) an assessment of the licensees capability to mitigate internal and external flooding events, as required by station design bases; and

(4) an assessment of the thoroughness of the walkdowns and inspections of important equipment needed to mitigate fire and flood events, which were performed by the licensee to identify any potential loss of function of this equipment during seismic events possible for the site.

b. Findings

NRC Inspection Report 05000338/2011010 (ML111330155) and 05000339/2011010 (ML111330155) documented detailed results of this inspection activity. Following issuance of the report, the inspectors conducted detailed follow-up on selected issues.

No findings were identified during this follow-up inspection.

.3 (Closed) NRC Temporary Instruction (TI) 2515/184, Availability and Readiness of

Severe Accident Management Guidelines (SAMGs)

On May 27, 2011, the inspectors completed a review of the licensees severe accident management guidelines (SAMGs), implemented as a voluntary industry initiative in the 1990s, to determine:

(1) whether the SAMGs were available and updated;

(2) whether the licensee had procedures and processes in place to control and update its SAMGs;

(3) the nature and extent of the licensees training of personnel on the use of SAMGs; and

(4) licensee personnels familiarity with SAMG implementation.

The results of this review were provided to the NRC task force chartered by the Executive Director for Operations to conduct a near-term evaluation of the need for agency actions following the Fukushima Daiichi fuel damage event in Japan. Plant-specific results for the North Anna Power Station were provided as an Enclosure to a memorandum to the Chief, Reactor Inspection Branch, Division of Inspection and Regional Support, dated June 02, 2011 (ML111530328).

.4 (Closed): Unresolved Item (URI) 05000338, 339/2009008-01, Qualification of Fire

Barrier Floor/Wall Penetration of Aluminum Conduit Through Sleeve

a. Inspection Scope

During a triennial fire protection inspection (TFPI) in 2009, inspectors opened URI 05000338; 339/2009008-01 to determine whether a performance deficiency existed relating to the qualification of aluminum conduits penetrating fire-rated barriers. The licensee subsequently performed testing and analyses of aluminum penetrations representative of those installed at the North Anna and Surry Nuclear Stations, and provided the results of those tests to the NRC. Region II fire protection inspectors performed in-office reviews of the licensees test results and analyses to verify the qualification of aluminum conduits installed in the plant. The inspectors also evaluated the significance of degraded fire barriers that contained conduit configurations that did not meet the acceptance criteria of the qualification tests. The licensees corrective actions were reviewed to ensure that they adequately restored compliance.

b. Findings

Introduction:

The inspectors identified a non-cited violation of the North Anna Power Station, Units 1 and 2 Renewed Facility Operating Licenses, NPF-4 & 7, Condition 2.D, Fire Protection, for failure to perform adequate qualification testing, as directed by Appendix A to Branch Technical Position (BTP) APCSB 9.5-1. Specifically, the licensee did not have sufficient testing results to qualify certain aluminum conduits that penetrate 3-hour fire rated barriers separating fire areas containing equipment required for fire safe shutdown.

Description:

During the 2009, NRC TFPI at the Surry Nuclear Station (SNS), NRC inspectors identified that documentation did not exist to qualify the use of aluminum conduit configurations penetrating horizontal or vertical fire-rated barriers. The penetration seal criteria established in BTP APCSB 9.5-1 states, in part, that penetrations through fire barriers, including conduits and piping, be sealed or closed to provide a fire resistance rating at least equal to that of the barrier itself. After completion of this inspection on June 26, 2009, North Anna Nuclear Station (NANS) staff determined the issue was also applicable to NANS. On June 29, 2009, the licensee entered the issue into the CAP as CR 342994. During the 2009 NRC TFPI at NANS, the inspectors requested the licensees documentation for the qualification of penetration seal configurations at NANS. In response, the licensee presented Installation Specification NAS-1024 for Silicone Foam in Fire Stops; Technical Report EP-0011; calculations 1250-111-C01, 1250-111-C03, 1250-111-C04; and Engineering Transmittal ET CEP 00-0025 that included Penetration Seal Configuration Evaluations. The team reviewed these documents and determined that the NANS testing addressed aluminum cable trays, but not aluminum conduit penetrations through fire barriers. The licensee entered this condition in the corrective action program as CR 347193, declared fire barriers with aluminum conduit penetrations potentially inoperable, and established compensatory fire watches.

After completion of the TFPI at NANS, the licensee performed qualification testing for aluminum conduits penetrating fire rated barriers at both SNS and NANS. Institute of Electrical and Electronics Engineers (IEEE) Standard 634-1978 was used to determine the acceptance criteria. The test results and licensee analyses concluded that certain fire barrier penetration configurations would not perform their design function. One of these configurations consisted of aluminum conduit greater than 2 in diameter with no internal silicone foam or smoke seals. The other configuration consisted of one internal seal installed partially within the plane of the surrounding fire barrier. This internal seal consisted of a nominal depth of 10 of silicone foam plus 1 of damming material. Both of these configurations would have allowed the temperature of cables on the unexposed side of the barrier to exceed the cables self-ignition temperature. The licensee compared the test results to the installed aluminum conduit population and determined that 128 conduits required modification in order to qualify as an acceptable configuration.

The licensee restored these conduit configurations to compliance by installing either Cerafiber (smoke seals) or silicone foam (Design Change NA-10-00116).

Analysis:

The inspectors identified a PD for the failure to perform adequate qualification testing of aluminum conduit configurations penetrating fire-rated barriers, as required by their approved fire protection program. The PD was more than minor and therefore a finding, because it is associated with the Reactor Safety Mitigating Systems cornerstone attribute of protection against external factors (i.e., fire) and it affects the cornerstone objective of ensuring the reliability and capability of systems that respond to initiating events. Specifically, not performing qualification testing of aluminum conduits that penetrate fire-rated barriers adversely affected the fire confinement capability defense-in-depth (DID) element because subsequent testing revealed conduits that did not meet criteria established in the licensees fire protection program. In accordance with NRC IMC 0609, Significant Determination Process, Appendix F, the inspectors performed a Phase 1 analysis. The team determined that this finding was in the Fire Confinement safe shutdown (SSD) category. The inspectors assessed the DID element of all fire barriers containing aluminum conduit greater than 2 in diameter, with no internal silicone foam or smoke seals, in the fire confinement category. Since the barrier type was unsealed conduit greater than 2 in diameter with greater than 3 feet on each side of barrier, the degradation level was categorized as Moderate A (in accordance with IMC 0609, Appendix F, Attachment 2, Table A2.2). Question 1 of IMC 0609, Appendix F, Task 1.3.2 screened the finding to very low safety significance (Green) due to all barriers providing a 2-hour or greater fire endurance rating. The inspectors assessed the DID element of 2 fire barriers containing one internal seal installed partially within the plane of the fire barrier in the fire confinement category. Since the untested conduit configuration contained between 9 and 11 depth of silicone foam, the degradation level was categorized as Moderate A (in accordance with IMC 0609, Appendix F, Attachment 2, Table A2.2). For each barrier, Question 4 of IMC 0609, Appendix F, Task 1.3.2 screened the finding to very low safety significance (Green) due to the rooms on each side of the barrier containing no equipment credited for fire safe shutdown of the plant.

The inspectors determined that no cross cutting aspect was applicable because this finding was not indicative of current licensee performance.

Enforcement:

North Anna Power Station, Units 1 & 2 Renewed Facility Operating Licenses, NPF-4 & 7, Condition 2.D, Fire Protection, states in part that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the licensees UFSAR for the facility and as approved in the SER dated February, 1979. The UFSAR, Section 9.5.1.1, Design Bases, states that the stations fire protection program satisfies the regulatory criteria set forth in Appendix A to BTP APCSB 9.5-1 of which Section C.5 states, in part, that a test program be established to assure that testing is performed to demonstrate conformance with design requirements.

Contrary to the above, the licensee failed to establish a test program to assure that aluminum conduit seal penetrations conformed to design requirements. This condition has existed since initial plant startup. Upon discovery, the licensee declared fire barriers with aluminum conduit penetrations potentially inoperable, and established applicable compensatory measures in accordance with ET-CEP-09-0010, Evaluation of Compensatory Measures for Aluminum Conduit Penetration Seal Issues, NANS Units 1 and 2, Revision 1, for 20 fire areas. Subsequently, the licensee performed testing to determine the qualification of aluminum conduit penetrations, and performed modifications, as necessary, to restore compliance. Because this finding is of very low safety significance and was entered in the licensees CAP as CR347193, this violation is treated as an NCV consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000338; 339/2011003-06, Inadequate Qualification Testing of Fire Barrier Penetration Seals.

.5 (Discussed) Evaluations of Changes, Tests, or Experiments and Permanent Plant

Modifications (Inspection Procedure 71111.17)

a. Inspection Scope

The inspectors reviewed selected samples of evaluations to confirm that the licensee had appropriately considered the conditions under which changes to the facility, Updated Final Safety Analysis Report (UFSAR), or procedures may be made, and tests conducted, without prior NRC approval. The inspectors reviewed evaluations for eight changes and additional information, such as drawings, calculations, supporting analyses, the UFSAR, and Technical Specifications (TS) to confirm that the licensee had appropriately concluded that the changes could be accomplished without obtaining a license amendment.

The inspectors reviewed samples of changes for which the licensee had determined that evaluations were not required, to confirm that the licensees conclusions to screen out these changes were correct and consistent with 10CFR50.59.

The inspectors evaluated engineering design change packages for 13 material, component, and design based modifications to evaluate the modifications for adverse effects on system availability, reliability, and functional capability. The 13 modifications and the affected cornerstones are as follows:

• DCP-06-103: Unit 1 and Unit 2 EDG Battery Charger Replacements (Mitigating Systems)

• DCP-06-119: Replace Unit 2 Substation Transformers 2A1/ 2A2 / 2H & 2H1 (Initiating Events)

• DCP-08-014: GSI-191 Unit 2 Containment Sump Strainer Seal Modifications (Mitigating Systems)

• DCP-08-103: Alternate Power Supply to Unit 1 SFP Cooling Pumps (Barrier Integrity)

• DCP-08-131: Tornado Driven Missile Protection of Unit 1 TDAFW Pump Exhaust (Mitigating Systems)

• IEE-10000002521: Emergency Diesel Generator Starting Air (Mitigating Systems)

• IEE-10000015657: Diesel Generator Fuel Oil Pump TOL Relay (Mitigating Systems)

• IEE-10000016211: Charging/HHSI Pump Motor Shaft Material (Mitigating Systems)

• NA-09-00113: Replace 1-HV-MOD-163A/B/C with Back Draft Dampers (Barrier Integrity)

• NA-09-00150: Replacement of 2-SI-MOV-2867B (Mitigating Systems)

• NA-10-00162: Recirculation Spray MOV Motor and TOL Replacement for 1-RS-MOV-156B (Barrier Integrity)

• PTE-9000337: Use of MOV Long-Life Grease (Mitigating Systems)

• PTE-10000001941: Replacement Parts for EDG Battery Charger (Mitigating Systems)

Documents reviewed included procedures, engineering calculations, modification design and implementation packages, work orders, site drawings, corrective action documents, applicable sections of the living UFSAR, supporting analyses, Technical Specifications, and design basis information. The inspectors additionally reviewed test documentation to ensure adequacy in scope and conclusion. The inspectors review was also intended to verify that all appropriate details were incorporated in licensing and design basis documents and associated plant procedures.

The inspectors also reviewed selected CRs and the licensees recent self-assessments associated with modifications and screening/evaluation issues to confirm that problems were identified at an appropriate threshold, were entered into the corrective action process, and appropriate corrective actions had been initiated and tracked to completion.

b. Findings and Observations

Following the performance of inspection activities on May 26, 2011, the inspectors continued to perform an in-office review of inspection-related information through the end of the reporting period on June 30, 2011. Additional review of inspection activities will be required to be performed during the reporting period of July 1, 2011 through September 30, 2011. The inspection results will be documented in the third quarter integrated inspection report (report number 2011004).

4OA6 Meetings, Including Exit

.1 Modifications Inspection Debrief Meeting

An inspection debrief meeting with Mr. Fred Mladen and other members of your staff was conducted on May 26, 2011, to discuss the progress of this inspection. Proprietary information reviewed by the team as part of routine inspection activities was either returned to the licensee or disposed of in accordance with prescribed controls.

.2 Exit Meeting Summary

On July 26, 2011, the senior resident inspector presented the inspection results to Mr.

Larry Lane and other members of the staff, who 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.

.3 Annual Assessment Meeting Summary

On April 4, 2011, the NRCs Deputy Director, Division of Reactor Projects, the NRC Chief of Reactor Projects Branch 5, and the Resident Inspectors assigned to the North Anna Power Station met with Virginia Electric and Power Company to discuss the NRCs Reactor Oversight Process and the NRCs annual assessment of North Annas safety performance for the period of January 1 through December 31, 2010. The major topics addressed were the NRCs assessment program, and the results of the North Anna Power Station assessment. Attendees included North Anna site management, members of the site staff, representatives from the local print and TV media, a representative from the Tokyo Newspaper, and fifteen members of the public.

This meeting was open to the public. The presentation material used for the discussion and the list of attendees is available from the NRCs document system (ADAMS) as accession number ML081200874. ADAMS is accessible from the NRC Web site at http://www/nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

4OA7 Licensee Identified Violations

The following violation of Severity Level IV was identified by the licensee and is a violation of NRC requirements which meet the criteria of the NRC Enforcement Policy, for characterization as a Non-Cited Violation.

• NUHOMS Certificate of Compliance 1030, Amendment 0, Technical Specifications 2.1.c, Functional and Operating Limits, requires, in part, that the spent nuclear fuel stored in each 32PTH DSC/HSM-H at the Independent Spent Fuel Storage Installation (ISFSI) is to be qualified for four

(4) heat load zones designated as Zones 1a, 1b, 2 and 3.

Contrary to this requirement, the licensee identified that it failed to properly load fuel assemblies into seven NUHOMS Dry Shielded Canisters (DSCs) resulting in the fuel assemblies exceeding the decay heat limit for the loading zones in two of the four center zones. Specifically, the Zone "1a" and Zone "1b" locations were reversed, resulting in the DSC Zone 1b heat load limits being exceeded (by less than 7.5 per cent in the worst case) at the time of loading. An evaluation performed by the licensee showed that all of the affected DSCs are currently in a safe condition as loaded in the HSMs.

This issue is in the licensees CAP as CR419242, NUHOMS DSCs Loaded to Incorrect Heat Load Limits for Specific Orientation. This Severity Level IV violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2.b of the NRC Enforcement Policy; specifically, the violation was identified by the licensee, the issue was placed into the licensees CAP, the violation was not repetitive as a result of inadequate corrective action, and the violation was not willful. Documents reviewed are listed in the Attachment to this report.

ATTACHMENT: SUPPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

W. Anthes, Manager, Nuclear Maintenance

M. Becker, Manager, Nuclear Outage and Planning

M. Crist, Plant Manager

R. Evans, Manager, Radiological Protection and Chemistry

T. Huber, Director, Nuclear Engineering

S. Hughes, Manager, Nuclear Operations

C. Gum, Manager, Nuclear Protection Services

L. Lane, Site Vice President

J. Leberstien, Technical Advisor Licensing

P. Kemp, Manager, Organizational Effectiveness

F. Mladen, Director, Station Safety and Licensing

G. Rossetti, Design Engineering

R. Scanlon, Manager, Nuclear Site Services

D. Taylor, Supervisor, Station Licensing

R. Wesley, Manager, Nuclear Training

M. Whalen, Technical Advisor Licensing

LIST OF ITEMS

Opened

05000338, 339/2011003-05 FIN-TBD Failure to Take Adequate Corrective Action to Preclude a Fire in the Units 1 and 2 Control Room Complex (Section 4OA3.2)

Opened and Closed

05000338/2011003-01 NCV Failure to Control Transient Fire Loads in a Safety-

Related Area (Section 1R05.1)

05000338, 339/2011003-02 NCV Failure to Maintain Fire Doors in Accordance with the Fire Protection Program (Section 1R05.2)

05000338, 339/2011003-03 NCV Failure to Comply with Technical Specifications for Alignment of the Refueling Water Storage Tank to the Non-Seismic Refueling Purification System.

(Section 1R18.2)

05000338/2011003-04 NCV Inadequate Cause Evaluation of Scaffolding Affecting Unit 1 A Charging Pump (Section 4OA2.3)

05000338, 339/2011003-06 NCV Inadequate Qualification Testing of Fire Barrier Penetration Seals (Section 4OA5.4)

Closed

05000338, 339/2009008-01 URI Qualification of Fire Barrier Floor/Wall Penetration of Aluminum Conduit Through Sleeve (Section 4OA5.4)

05000338/2010-005-00 LER Unanalyzed Scaffolding Renders Charging Pump Inoperable Due to Human Error (Section 4OA3.1)

05000338/2011-001-00 LER Annuciator Card Failure Due to Carbon Resistor Degradation (Section 4OA3.2)

05000338, 339/2515/183 TI Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event (Section 4OA5.2)

05000338, 339/2515/184 TI Availability and Readiness of Severe Accident Management Guidelines (SAMGs) (Section 4OA5.3)

Discussed

05000338, 339/2515/71111.17 BI Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications (Section 4OA5.5)