IR 05000338/2013008
| ML13129A204 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/09/2013 |
| From: | Curtis Rapp Reactor Projects Branch 7 |
| To: | Heacock D Virginia Electric & Power Co (VEPCO) |
| References | |
| IR-13-008 | |
| Download: ML13129A204 (18) | |
Text
UNITED STATES May 9, 2013
SUBJECT:
NORTH ANNA POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000338/2013008 AND 05000339/2013008
Dear Mr. Heacock:
On March 28, 2013, 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 March 28, 2013, with Mr. G. Bischof 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.
Based on the inspection sample, the inspection team concluded that the implementation of the corrective action program and overall performance related to identifying, evaluating, and resolving problems at North Anna Power Station Units 1 and 2 was adequate. Licensee identified problems were entered into the corrective action program at a low threshold.
Problems were generally prioritized and evaluated commensurate with the safety significance of the problems. Corrective actions were generally implemented in a timely manner commensurate with their importance to safety and addressed the identified causes of problems.
Lessons learned from the industry operating experience were generally reviewed and applied when appropriate. Audits and self-assessments were effectively used to identify problems and appropriate actions. One self-revealing finding was identified which did not involve a violation of NRC requirements. 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 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/
Curtis W. Rapp, Chief Reactor Projects Branch 7 Division of Reactor Projects Docket Nos. 50-338, 50-339 License Nos. NPF-4, NPF-7
Enclosure:
INSPECTION REPORT 05000338/2013008 AND 05000339/2013008 w/Attachment: Supplemental Information
REGION II==
Docket Nos.: 05000338, 05000339 License Nos.: NPF-4, NPF-7 Report Nos.: 05000338/2013008 and 05000339/2013008 Licensee: Virginia Electric and Power Company Facility: North Anna Power Station, Units 1 and 2 Location: Mineral, VA Dates: March 11 - 15, 2013 March 25 - 29, 2013 Inspectors: R. Taylor, Senior Project Inspector, Team Leader R. Clagg, Resident Inspector, North Anna S. Ninh, Senior Project Engineer J. Quinones, Project Engineer C. Scott, Resident Inspector, Robinson Approved by: C. Rapp, Chief, Reactor Projects Branch 7 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000338/2013-008 and 05000339/2013-008; March 11, 2013 - March 25, 2013; North
Anna Power Station Units 1 and 2; Biennial Inspection of the Problem Identification and Resolution Program.
The inspection was conducted by a senior project inspector, senior project engineer, project engineer, and two resident inspectors. One Green Finding was identified. The significance of inspection findings are identified by their color i.e. (greater than Green, or Green, White, Yellow, or Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP) dated June 2, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated June 7, 2012. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4.
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.
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. Operating experience usage was found to be generally acceptable and integrated into the licensees processes for performing and managing work, and plant operations.
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.
Cornerstone: Initiating Events
Green: A self-revealing finding was identified for failure to establish and implement appropriate periodic preventive maintenance for replacement frequency of the C4 capacitor on the Speed Error Amplifier card B (1A08D) in accordance with VPAP-803, Preventive Maintenance Program. Consequently, the C4 capacitor failed due to age related degradation and caused an automatic reactor trip from 100 percent reactor power.
The licensees failure to establish and implement appropriate periodic preventive maintenance for replacement frequency of the C4 was a performance deficiency. The finding was more than minor because it was associated with the Initiating Events cornerstone attribute of equipment performance and adversely affected the associated cornerstone in that a reactor trip occurred.
The finding was determined to be of very low safety significance (Green) because it was a transient initiator, but did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. The finding did not have a cross-cutting aspect because the performance deficiency was not indicative of current plant performance.
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
.1 Assessment of the Corrective Action Program
a. 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 March 2011 and March 2013, including a detailed review of selected CRs associated with the following risk-significant systems: AC Electrical Power (AC), Safety Injection (SI), and Emergency Diesel Generators (EDG). 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 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 operations, maintenance, engineering, health physics, chemistry, and security. These CRs were reviewed to assess the threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions.
The inspectors conducted plant walkdowns to assess the material condition and to identify 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 to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period; 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. 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 for significant conditions adverse to quality.
The inspectors attended the Condition Report Review Team (CRT) and Corrective Action Assignment Review Team (CAART) meetings to observe management oversight functions of the corrective action process.
Documents reviewed are listed in the Attachment.
.b 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, management expectation that employees were encouraged to initiate CRs for any reason, and the relatively few number of deficiencies identified 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.
Prioritization and Evaluation of Issues 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. 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 PI-AA-300-3001, Root Cause Evaluation and PI-AA-300-3002, Apparent Cause Evaluation.
Effectiveness of Corrective Actions The inspectors determined that overall, corrective actions were timely, commensurate with the safety significance, and effective, in that conditions adverse to quality were corrected. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence. Effectiveness reviews for corrective actions to prevent recurrence (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.
c. Findings
No findings were identified.
.2 Assessment of the Use of Operating Experience (OE)
a. Inspection Scope
The inspectors examined licensee programs for reviewing industry OE, reviewed licensee procedure PI-AA-100-1007, Operating Experience Program, reviewed the licensees OE database to assess the effectiveness of how external and internal OE data was handled. In addition, the inspectors selected OE 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 February 2011, to verify if the licensee had appropriately evaluated each notification for applicability, and if 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.
b. Assessment 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.
c. Findings
No findings were identified.
.3 Assessment of Self-Assessments and Audits
a. 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 procedure PI-AA-100-1004, Self Assessments.
b.
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.
c. Findings
No findings were identified.
4. Assessment of Safety-Conscious Work Environment
a. Inspection Scope
The inspectors randomly interviewed several on-site workers regarding their knowledge of the CAP 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 coordinator.
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.
b. Assessment 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, 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.
c. Findings
No findings were identified.
4OA3 Event Followup
.1 (Closed) Licensee Event Report (LER) 50-339/2102-001-00, Automatic Reactor Trip
Resulting From A Card Failure
a. Inspection Scope
The inspectors reviewed the LER and associated CRs to assess if the issue was properly identified, documented accurately and completely, properly classified and prioritized, adequately considered extent of condition, generic implications, common cause, and previous occurrences, adequately identified root causes/apparent causes, and identified appropriate and timely corrective actions. Also, the inspectors verified the issue was processed in accordance with procedure, PI-AA-200, Revision 20.
b. Findings
Introduction:
A Green self-revealing finding was identified for failure to establish and implement appropriate periodic preventive maintenance for replacement frequency of the C4 capacitor on the Speed Error Amplifier card B (1A08D) in accordance with the VPAP-803, Preventive Maintenance Program.
Description:
On October 24, 2012, Unit 2 reactor automatically tripped from 100 percent reactor power due to a steam generator Lo-Lo level signal resulting from closure of all four turbine governor valves. The governor valves closed due to a spurious error signal from Speed Error Amplifier card B (1A08D). The card malfunction was the result of a failed C4 capacitor.
The licensee concluded that the C4 capacitor replacement frequency was not implemented in accordance the vendors recommendations. This capacitor was determined to have a life expectancy of approximately 7.5 years and a shelf life not to exceed 3 years including time spent in manufacturer storage and customer storage. The capacitor was manufactured in May 1999, installed on the original circuit card of the electro hydraulic control (EHC) system on October 17, 2002, and failed on October 24, 2012. No provision was established to adjust the PM frequency, if required, for life cycle time used while the capacitor was being stored after manufacturing and prior to installation on the card.
The inspectors verified that Step 6.4.2.d of procedure VPAP-0602, Vendor Technical Manual Control (VTM), revision 5, stated that maintenance shall review maintenance procedures to ensure that maintenance practices are consistent with VTM. Step 6.2.7 of VPAP-803, Preventive Maintenance Program, revision 18, also stated that the evaluator shall determine the PM requirements by analyzing the failure history and vendor maintenance recommendations while considering the function and important of the component. The licensee established the PM requirements for the C4 capacitor based on a memorandum from the circuit card vendor of a 20 year lifetime. However, this lifetime was based on the originally installed capacitor. The licensee did not have an evaluation to justify the 20 year PM frequency for the replacement C4 capacitor and failed to incorporate the capacitor vendor lifetime of 7.5 years into the PM frequency. A corrective action to prevent recurrence was to revise VPAP-803 to ensure that component level replacement recommendations are obtained from component manufacturer guidance.
Analysis:
The inspectors determined that the licensees failure to establish and implement appropriate periodic preventive maintenance for replacement frequency of the C4 capacitor on the Speed Error Amplifier card B (1A08D) in accordance with the vendors recommendations was a performance deficiency. The PD was more than minor because it was associated with the Initiating Events cornerstone attribute of equipment performance and adversely affected the associated cornerstone objective in that age-related failure of the C4 capacitor resulted in a reactor trip. Using NRC Manual Chapter 0609.04, SDP - Phase 1 screening dated June 19, 2012, the finding was determined to be of very low safety significance (Green) because it was a transient initiator, but did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. The finding did not have a cross-cutting aspect because the performance deficiency was not indicative of current plant performance.
Enforcement:
This finding did not involve enforcement action. This finding was determined to be of very low safety significance (Green) and was entered into the licensees CAP as CR493091. This finding is identified as FIN 05000339/2013008-01, Failure to Implement Vendor Recommendations Causes an Automatic Reactor Trip.
4OA6 Exit
Exit Meeting Summary
On March 28, 2013, the inspectors presented the inspection results to Mr. G. Bischof 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
- G. Bischof, Site Vice President
- F. Mladen, Plant Manager
- B. Anhold, Component Engineer
- J. Daugherty, Manager Maintenance
- E. Hendrixson, Site Engineering Director
- P. Kemp, Licensing Supervisor
- J. Leberstien, Licensing
- S. Morris, Engineering Programs Manager
- J. Schleser, Organizational Effectiveness Manager
NRC personnel
- G. Kolcum, Senior Resident Inspector
- G. Hopper, Chief, Branch 7, Division of Reactor Projects
LIST OF REPORT ITEMS
Opened and Closed
- 05000339/2013-008-01 FIN
- 05000339/2013008-01 Failure to Implement Vendor Recommendations Causes an Automatic Reactor Trip
Closed
- 05000339/2012-001-00 LER Automatic Reactor Trip Resulting From A Card Failure (Section 4OA3)