IR 05000338/2011008

IR 05000338-11-008, 05000339-11-008; April 11 - 29, 2011; North Anna Power Station, Units 1 and 2; Biennial Inspection of the Problem Identification and Resolution Program

ML111600316
Person / Time
Site:	North Anna
Issue date:	06/09/2011
From:	Hopper G NRC/RGN-III/DRP/RPB7
To:	Heacock D Virginia Electric & Power Co (VEPCO)
References
IR-11-008
Download: ML111600316 (19)

Text

UNITED STATES une 9, 2011

SUBJECT:

NORTH ANNA POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000338/2011008 AND 05000339/2011008

Dear Mr. Heacock:

On April 29, 2011, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your North Anna Power Station Units 1 and 2. The enclosed report documents the inspection findings, which were discussed on April 29, 2011, with Mr. Lane and other members of your staff.

The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of plant equipment and activities, and interviews with personnel.

On the basis of the samples selected for review, there were no findings identified during this inspection. The inspectors concluded that problems were properly identified, evaluated, and resolved within the corrective action program (CAP). However, during the inspection, some minor performance deficiencies were identified related to your prioritization and evaluation of identified problems and your adherence to site procedures associated with the self-assessment program.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure 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

VEPCO 2 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/

George T. Hopper, Chief Reactor Projects Branch 7 Division of Reactor Projects Docket No. 50-338, 50-339 License No. NPF-4, NPF-7

Enclosure:

Inspection Report 05000338/2011008 and 05000339/2011008 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-338, 50-339 License Nos.: NPF-4, NPF-7 Report Nos.: 05000338/2011008 and 05000339/2011008 Licensee: Virginia Electric Power Company Facility: North Anna Power Station, Units 1 and 2 Location: Mineral, VA Dates: April 11 - 15, 2011 April 25 - 29, 2011 Inspectors: M. Cain, Senior Resident Inspector, Vogtle, Team Leader M. King, Senior. Project Engineer S. Rose, Senior Project Engineer C. Sanders, Project Manager, NRR Approved by: G. Hopper, Chief, Reactor Projects Branch 7 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000338/2011008, 05000339/2011008; April 11 - 29, 2011; North Anna Power Station,

Units 1 and 2; Biennial Inspection of the Problem Identification and Resolution Program.

The inspection was conducted by two senior project engineers, one project manager, and a senior resident inspector. No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Identification and Resolution of Problems The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution, as evidenced by the relatively few number of deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee, during the review period. Generally, prioritization and evaluation of issues were adequate, formal root cause evaluations for significant problems were adequate, and corrective actions specified for problems were acceptable. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner. However, the inspectors did identify minor performance deficiencies associated with the CAP in the areas of problem identification, prioritization and evaluation of identified problems, and effectiveness of corrective actions.

The inspectors determined that overall; audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the CAP, and appropriate corrective actions were developed to address the issues identified. However, the inspectors identified a minor performance deficiency associated with the self-assessment program. Operating experience usage was found to be generally acceptable and integrated into the licensees processes for performing and managing work, and plant operations. However, the inspectors identified minor performance deficiencies associated with the licensees use of operating experience.

Based on discussions and interviews conducted with plant employees from various departments, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP to resolve those concerns.

REPORT DETAILS

4OA2 Problem Identification and Resolution

a. Assessment of the Corrective Action Program

(1) Inspection Scope The inspectors reviewed the licensees CAP procedures which described the administrative process for initiating and resolving problems primarily through the use of condition reports (CRs). To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the inspectors reviewed CRs that had been issued between February 2009 and March 2011 including a detailed review of selected CRs associated with the following risk-significant systems: AC Electrical Power, Main Steam (MS), and Quench Spray/Recirculation Spray (QS/RS). Where possible, the inspectors independently verified that the corrective actions were implemented as intended. The inspectors also reviewed selected common causes and generic concerns associated with root cause evaluations (RCEs) to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the NRCs Reactor Oversight Process (ROP), the inspectors selected a representative number of CRs that were identified and assigned to the major plant departments, including operations, maintenance, engineering, health physics, chemistry, and security. These CRs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The inspectors reviewed selected CRs, verified corrective actions were implemented, and attended meetings where CRs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.

The inspectors conducted plant walkdowns of equipment associated with the selected systems and other plant areas to assess the material condition and to look for any deficiencies that had not been previously entered into the CAP. The inspectors reviewed CRs, maintenance history, completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period of time; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-dependent issues.

Control Room walkdowns were also performed to assess the main control room (MCR)deficiency list and to ascertain if deficiencies were entered into the CAP. Operator Workarounds and Operator Burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the field.

The inspectors conducted a detailed review of selected CRs to assess the adequacy of the root-cause and apparent-cause evaluations of the problems identified. The inspectors reviewed these evaluations against the descriptions of the problem described in the CRs and the guidance in licensee procedure PI-AA-300-3001, Root Cause Evaluation and PI-AA-300-3002, Apparent Cause Evaluation. The inspectors assessed if the licensee had adequately determined the cause(s) of identified problems, and had adequately addressed operability, reportability, common cause, generic concerns, extent-of-condition, and extent-of-cause. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence.

The inspectors reviewed selected industry operating experience items, including NRC generic communications to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP.

The inspectors reviewed site trend reports to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.

The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included Condition Report Review Team (CRT) screening meetings and Corrective Action Review Team meetings.

Documents reviewed are listed in the Attachment.

(2) Assessment Identification of Issues The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was a low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating CRs as described in licensee procedure PI-AA-200, Corrective Action, managements expectation that employees were encouraged to initiate CRs for any reason, and the relatively few number of deficiencies identified by inspectors during plant walkdowns not already entered into the CAP. Trending was generally effective in monitoring equipment performance. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues.

Based on reviews and walkdowns of accessible portions of the selected systems, the inspectors determined that most system deficiencies were being identified and placed in the CAP, however, there were issues identified by inspectors during system walk downs which were not previously identified or entered in your CAP. The following is summary of the issues identified by the team during plant walk-downs and through the course of the inspection which have now been entered into your corrective action program. These issues were screened in accordance with Manual Chapter 0612, Issue Screening, and were determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.

• Inspectors identified that the spring cans within two feet of Unit 1 and 2 MS dump valves were found to have inconsistent welds. CRs 422189 (U1) and CR 422193 (U2) documented these inconsistencies. The unexpected welds were between the pipe stanchion sliding plate and the spring can load column. One existing weld at the 2-SHP-SH-99 support near 2-MS-TCV-2408A, was identified as not being consistent with the Grinnell sketches. The Grinnell sketch identifies that this junction should be free to slide, therefore, a Work Order has been initiated to grind out this weld. This was determined to be not more than minor since the valves are not safety related and no binding or support problems were evident.

• Inspectors identified that several Unit 1 and 2 main steam trip valves (MSTV)instrument air (IA) supply flex hoses have either missing IA tubing clamps or loose clamps. CRs 422209 (U1) and CR 422207 (U2) documented these clamp issues. This condition was not in compliance with specification NAI-0001/SUI-0001, Rev. 8. The licensees civil engineering determined that there was no immediate threat to the IA service for these valves (during normal operation or design bases events (i.e. not more than minor)); however, it was determined that additional supports / adjustments should be implemented at the next available maintenance window.

• Inspectors identified a missing electrical duct seal from the connector at the termination for the E-transfer buss which had not been previously identified.

CR422274 documents this condition.

Prioritization and Evaluation of Issues Based on the review of CRs sampled by the inspection team during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in the CR severity level determination guidance in PI-AA-200, Corrective Action. Each CR was assigned a severity level at the CRT meeting, and adequate consideration was given to system or component operability and associated plant risk.

The inspectors determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures and assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used depending on the type and complexity of the issue consistent with procedures PI-AA-300-3001 and PI-AA-300-3002.

The inspectors identified six performance deficiencies associated with the licensees prioritization and evaluation of issues. These issues were screened in accordance with Manual Chapter 0612, Issue Screening, and were determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.

• Inspectors identified that a CR (CR423620), associated with emergency switchgear room ac unit # 7 circuit breaker, did not receive an adequate review during the CRT screening process and subsequently seismic qualification, extent of condition and common cause attributes would not have been addressed.

Corrective action CA199130 documents this issue.

• During review of RCE 976, Failure of Control Rod Drive Mechanism (CRDM) fan circuit breaker(1-EE-BKR-1J1-2S-J1), two deficiencies were noted:

.

a.

The CAP matrix in the RCE did not include effectiveness measures for the CAPRs as required by procedure PI-AA-200, and the actions listed in the matrix did not match the actions in the corrective action section of the RCE. CR 424665 documents this issue.

b.

The RCE quality index did not identify the lack of measures of effectiveness and was not attached to the CR. CR 424665 documents this issue.

• RCE 978 did not have a Corrective Action Matrix as required by procedure PI-AA-300-3001, Root Cause Evaluation, step 3.3.16. CR 424665 documents this issue.

• Two RCEs (RCE 976 and 978) were identified which did not include effectiveness measures for the CAPRs as required by procedure PI-AA-300. CR 424665 documents this issue.

• CR 412104 written to address a Green NCV with a cross-cutting aspect (p.1.c -

citing inadequate evaluation which led to failure to take adequate action to address extent of condition associated with fatigued fuse clips) was closed to a different CR, without an evaluation of the cross-cutting aspect. CR 422202 documents this issue.

• Assumptions made in Prompt Operability Determination (OD411) (which justified continued operation of the Reserve Station Service Transformer (RSST)

Reinhausen TAPCON Load Tap Changers on A and C RSSTs) were not challenged and the OD was not revised when indications of unusual behavior was observed from C RSST on April 14, 2011. CR 424884 documents this issue.

Effectiveness of Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected and non-recurring. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, CRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.

The inspectors identified five performance deficiencies. These issues were screened in accordance with Manual Chapter 0612 and were determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.

• Review of Apparent Cause Evaluation (ACE) 18202, which evaluated the occurrence of not isolating primary grade (PG) water in accordance with TS 3.1.8 following the reactor trip that occurred due to a lightning strike in the switchyard, revealed that CA171589, which was to evaluate TS 3.1.8 changes to lengthen the time requirements or method for verification of no PG water dilution, was canceled. The justification for canceling the CA was based on procedure revisions that would ensure that TS 3.1.8 requirements would be satisfied.

However, the inspector identified that ECA-0.0, Loss of All AC Power, did not include steps to isolate the PG path, as did other emergency operating procedures. CR 424613 documents the need for determining if steps need to be added to ECA-0.0.

• Inspectors noted during the review of CR 4033015 and CA 187096 that the assignment to review the applicability of inadvertent manipulation of the EDG governor oil drain petcock to the SBO diesel was never performed. Due to the cancellation and reassignment of this activity, the SBO diesel was never evaluated. CR 424244 was initiated to document this condition.

• ACE13882 to address Nuclear Oversight AFI 08-012-N (insufficient methods applied to review of industry OpE resulted in failures to identify measures that could have prevented events and equipment failures):

a. A corrective action review board (CARB) recommended action to provide monthly report to supervision and management of operating experience (OE) not screened within 30 days was closed, but the monthly report was discontinued after 5 months at the discretion of the OE coordinator.

b. Two RCEs 978 and 1007 were identified which did not have the required note regarding handling of OE reviews included in the detailed assignment which was required by corrective actions in CA083475. The note was subsequently added.

• During review of RCE 976, Failure of Control Rod Drive Mechanism (CRDM) fan circuit breaker (1-EE-BKR-1J1-2S-J1), inspectors identified that CAPR 469 was inappropriately closed before all breaker contactors had been replaced.

Contrary to procedural requirement in PI-AA-200, the CAPR was closed to scheduled PMs which could be extended without a CARB review. CR 424717 documents this issue.

(3) Findings

Introduction:

The team identified an unresolved item (URI) concerning the seismic qualification of safety related breakers with thermal overloads that are not securely attached in their mounting base.

Description:

While observing the conduct of the daily condition report review (CRT)meeting, Inspectors questioned the licensees disposition of CR423620, Thermal Overload Popped Out of Base. The licensee review team had dispositioned the CR as closed to work performed with no further action required. Inspectors challenged that disposition and questioned whether the licensee had considered past operability, seismic qualification, extent of condition and common cause attributes. As a result of the inspectors questions, the licensee re-reviewed the CR the following day and initiated follow on corrective action assignments to address each of the inspectors concerns.

The CR description stated, While performing tool pouch work on 59-01-EE-BKR-1J1-1-F1-CKTBRK, Emergency Switchgear Room A/C Unit 7 Circuit Breaker, to replace the bulb on the green indicating lamp, electricians noted that the thermal overload module had popped out of its mounting base. Thermal overload needs to be snapped back into base and seated properly to ensure reset rod lines up to reset button and to re-train field cables to relieve stress on electrical connections. Electricians secured the thermal overload within mounting base and rerouted field wiring to relieve stress on the thermal overload module. Subsequent interviews with electricians involved with the incident as well as several other electrical staff members revealed that this was the first instance of this particular deficient condition.

The licensee is currently in the process of having a third party independent laboratory seismically test this type of safety related breaker with its thermal load in a condition similar to the as-found condition to address past operability concerns. Inspectors concluded that further review of information related to seismic testing results is necessary to determine if the issue constitutes a violation of regulatory requirements.

This issue is identified as URI 05000338/2011008-01, Seismic Qualification of Safety Related Breakers with Thermal Overload Unsecured.

b. Assessment of the Use of Operating Experience (OE)

(1) Inspection Scope The inspectors examined licensee programs for reviewing industry operating experience, reviewed licensee procedure PI-AA-100-1007, Operating Experience Program, reviewed the licensees operating experience database to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the inspectors selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal operating experience items, etc.), which had been issued since December 2008 to verify whether the licensee had appropriately evaluated each notification for applicability to the North Anna plant, and whether issues identified through these reviews were entered into the CAP. Procedure PI-AA-100-1007, "Operating Experience Program," was reviewed to verify that the requirements delineated in the program were being implemented at the station. Documents reviewed are listed in the Attachment.

(2) Assessment Based on a review of documentation related to the review of operating experience issues, the inspectors determined that the licensee was generally effective in screening operating experience for applicability to the plant. Industry OE was evaluated by plant OE Coordinators and relevant information was then forwarded to the applicable department for further action or informational purposes. OE issues requiring action were entered into the CAP for tracking and closure. In addition, operating experience was included in all root cause evaluations in accordance with licensee procedure PI-AA-300-3001.

Two performance deficiencies were identified. These issues were screened in accordance with Manual Chapter 0612 and were determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.

• At the time of the inspection, inspectors noted a backlog of 199 OE items received during the period March 1, 2011 through April 19, 2011 which had not been screened by the OE Coordinator due to conflicting duties. Inspectors determined that a recently completed Nuclear Oversight Assessment (11-06-N)of OE also noted the backlog, but did not identify the issue associated with the OE Coordinator not having a backup to screen OE items during periods of conflicting duties. CR 422166 documents this issue.

• Three OE items, which were received in February 2011, were still open and awaiting a response from the subject matter expert (SME) for over 30 days, which exceeded the time allowed in procedure PI-AA-100-1007. CR 422166 documents this issue.

(3) Findings No findings were identified.

c. Assessment of Self-Assessments and Audits

(1) Inspection Scope The inspectors reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedures PI-AA-100-1003, Self Evaluation, PI-AA-100-1004, Formal Self-Assessments, and PI-AA-100-1005, Informal Self-Assessments.

(2) Assessment The inspectors determined that the scopes of assessments and audits were adequate.

Self-assessments were generally detailed and critical, as evidenced by findings consistent with the inspectors independent review. The inspectors verified that CRs were created to document all areas for improvement and findings resulting from the self-assessments, and verified that actions had been completed consistent with those recommendations. Generally, the licensee performed evaluations that were technically accurate. Site trend reports were thorough and a low threshold was established for evaluation of potential trends, as evidenced by the CRs reviewed that were initiated as a result of adverse trends.

The inspectors identified one performance deficiency associated with the licensees self-assessment program. This issue was screened in accordance with Manual Chapter 0612 and was determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.

• PI-AA-100-1004, Formal Self-Assessments, requires team leaders to complete self-assessment Computer Based Training within the last 36 months. This could not be validated for three self assessment team leaders. CR 422221 documents this issue.

(3) Findings No findings were identified.

d.

Assessment of Safety-Conscious Work Environment

(1) Inspection Scope The inspectors randomly interviewed 20 on-site workers regarding their knowledge of the corrective action program at North Anna and their willingness to write CRs or raise safety concerns. During technical discussions with members of the plant staff, the inspectors conducted interviews to develop a general perspective of the safety-conscious work environment at the site. The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors reviewed the licensees Employee Concerns Program (ECP) and interviewed the ECP manager. Additionally, the inspectors reviewed a sample of ECP issues to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.

(2) Assessment Based on the interviews conducted and the CRs reviewed, the inspectors determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees.

Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.

(3) Findings No findings were identified.

4OA6 Meetings, Including Exit

On April 29, 2011, the inspectors presented the inspection results to Mr. L. Lane and other members of the site staff. The inspectors confirmed that all proprietary information examined during the inspection had been returned to the licensee.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

M. LaPrade, Supervisor, Systems Engineering

P. Harper, Engineer III, Station Nuclear Safety

J. Lieberstein, Technical Advisor, Station Licensing

B. Belcher, Employee Concerns Program Manager

B. Jones, Quality Inspection Coordinator

W. Hunsberger, Systems Engineering

L. Lane, Site Vice President

M. Crist, Plant General Manager

M. Whalen, Technical Specialist

W. Anthes, Manager Nuclear Maintenance

R. Klearman, Supervisor, Site Nuclear Safety

T. Huber, Engineering Director

M. Becker, Manager, Outage & Planning

M. Schry, Supervisor, Nuclear Shift Operations

W. Hunsberger, Supervisor Electrical Systems and I&C

S. HcHugh, Electrical Systems Engineer

J. Warchol, Electrical Systems Engineer

M. Main, Breaker Component Engineer

J. George, OE Coordinator

NRC personnel

J. Reece, Senior Resident Inspector

C. Sanders, Resident Inspector (Temporary)

G. Hopper, Chief, Branch 7, Division of Reactor Projects

LIST OF REPORT ITEMS

Opened

05000338/2011008-01 URI Seismic Qualification of Safety Related Breakers with Thermal Overload Unsecured (Section 4OA2.a(3))

Closed

None

Discussed

None