IR 05000338/2015004

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NRC Integrated Inspection Report 05000338/2015004 and 05000339/2015004
ML16029A024
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 01/29/2016
From: Steven Rose
NRC/RGN-II/DRP/RPB5
To: Heacock D
Virginia Electric & Power Co (VEPCO)
References
IR 2015004
Download: ML16029A024 (23)
v • d • e


Text

UNITED STATES ary 29, 2016

SUBJECT:

NORTH ANNA POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000338/2015004 and 05000339/2015004

Dear Mr. Heacock:

On December 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your North Anna Power Station, Units 1 and 2. On January 25, 2016, the NRC inspectors discussed the results of this inspection with Mr. G. Bischof and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented one finding which was determined to be of very low safety significance (Green) in this report. This finding involved a violation of NRC requirements.

Further, inspectors documented two licensee-identified violations which were determined to be of very low safety significance. The NRC is treating these findings as non-cited violations (NCVs) consistent with Section 2.3.2 of the NRC Enforcement Policy.

If you contest the violations or significance of these NCVs, 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 20555-0001; 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.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days 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 in accordance with Title 10 Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "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 System (PARS)

component of NRC's Agencywide Documents Access and Management 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/

Steven D. Rose, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket Nos.: 05000338, 05000339 License Nos.: NPF-4, NPF-7 Enclosure:

IR 05000338/2015004 and 05000339/2015004 w/Attachment: Supplementary Information Distribution via Listserv

ML16029A024 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DRP RII:DRP RII:DRP RII:DRS RII:DRP RII:DRP RII:DRS SIGNATURE GC via email GC /RA for/ via email GK via Email DB via Email BDB3 SON GM via Email NAME GCroon GEatmon GKolcum DBacon BBishop SNinh GMacDonald DATE 1/25/2016 1/25/2016 1/26/2016 1/26/2016 1/20/2016 1/21/2016 1/26/2016 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICE RII:DRP SIGNATURE SDR2 NAME SRose DATE 1/28/2016 E-MAIL COPY? YES NO Letter to David from Steven D. Rose dated January 29, 2016 SUBJECT: NORTH ANNA POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000338/2015004 AND 05000339/2015004 DISTRIBUTION:

S. Price, RII D. Gamberoni, RII L. Gibson, RII OE Mail RIDSNRRDIRS PUBLIC RidsNrrPMNorthAnna Resource

U.S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket Nos: 50-338, 50-339 License Nos: NPF-4, NPF-7 Report No: 05000338/2015004 and 05000339/2015004 Licensee: Virginia Electric and Power Company (VEPCO)

Facility: North Anna Power Station, Units 1 & 2 Location: Mineral, Virginia 23117 Dates: October 1, 2015 through December 31, 2015 Inspectors: B. Bishop, Project Engineer G. Croon, Senior Resident Inspector G. Eatmon, Resident Inspector G. Kolcum, Senior Resident Inspector D. Bacon, Senior Operations Engineer (Section 1R11.3)

Approved by: Steven D. Rose, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY

IR 05000338/2015-004, 05000339/2015-004; 10/01/2015 - 12/31/2015; North Anna Power

Station, Units 1 and 2. Maintenance Effectiveness.

The report covered a three-month period of inspection by resident inspectors and inspectors from the regional office. One self-revealing finding was identified and was determined to be a non-cited violation (NCV). The significance of most findings is indicated by their color (Green,

White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated April 29, 2015. The cross-cutting aspects are determined using IMC 0310, Components Within the Cross Cutting Areas, dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated February 4, 2015. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

Cornerstone: Mitigating Systems

Green.

A self-revealing, Green NCV of TS 5.4.1.a, "Procedures," as required by Regulatory Guide 1.33, Revision 2, Appendix A, Section 9a, Procedures for Performing Maintenance, was identified for inadequate implementation of licensee procedure MA-AA-102, Attachment 4, "Foreign Material Exclusion," Part D Closeout Inspections Revision 15, which resulted in foreign material intrusion into the B SW return header The licensee has entered this issue into their corrective action program as CR1010424.

The inspectors identified a performance deficiency (PD) for the failure to adequately implement the foreign material exclusion maintenance procedure MA-AA-102, Attachment 4,

"Foreign Material Exclusion," Part D Closeout Inspections Revision 15. The inspectors determined that the PD was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstone objective to ensure the availability of systems that respond to initiating events to prevent undesirable consequences, (i.e., core damage). Specifically, the inadequate FME closeout led to foreign material intrusion into the B SW return header when maintenance materials, such as plastic bags and mop heads, were not removed and made their way into the B SW return header. The inspectors used Manual Chapter (IMC) 0609, Attachment 4,

Initial Characterization of Findings, dated June 19, 2012, and determined that the finding was of very low safety significance or Green because the B SW return header did not have an actual loss of safety function for greater than its allowed outage time (7 days). The finding had a cross-cutting aspect in the area of Human Performance, Work Management component, because licensee personnel did not follow procedure requirements of MA-AA-102, Attachment 4, "Foreign Material Exclusion," Part D Closeout Inspections Revision 15 during the return to service portion of the work activity for the B SW return header. [H.5]

Two violations of very low safety significance that were identified by the licensee have been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. The violations and corrective action tracking numbers 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). Unit 1 operated at full power for the remainder of the report period.

Unit 2 began the period at full RTP. Unit 2 experienced a level controller problem with a feed water heater and reduced power to 97% for replacement on November 23, 2015. Unit 2 returned to full RTP on November 25, 2015. Unit 2 operated at full RTP for the remainder of the report period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors performed a site specific weather related inspection due to anticipated adverse weather conditions. On October 1, 2015, the inspectors reviewed the licensees preparations for response to heavy winds and rains in the area from Hurricane Joaquin.

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.

1R04 Equipment Alignment

Partial Walkdowns

a. Inspection Scope

The inspectors conducted three equipment alignment partial walkdowns, listed below, to evaluate the operability of selected redundant trains or backup systems with the other train or system inoperable or out of service. The inspectors reviewed the functional 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 the operability of a redundant or backup system/train or a remaining operable system/train with a high risk significance for the current plant configuration (considering out-of-service, inoperable, or degraded condition); or a risk-significant system/train that was recently realigned following an extended system outage, maintenance, modification, or testing; or a risk-significant single-train system. The inspector conducted the reviews to ensure that critical components were properly aligned, and to identify any discrepancies which could affect operability of the redundant train or backup system.

  • Unit 1 outside recirculation spray system

b. Findings

No findings were identified.

1R05 Fire Protection

Quarterly Fire Protection Walkdowns

a. Inspection Scope

The inspectors conducted focused tours of the five 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, Fire Protection/Appendix R (Fire Safe Shutdown) Program, Revision 10, CM-AA-FPA-101, Control of Combustible and Flammable Materials, Revision 8, and CM-AA-FPA-102, Fire Protection and Fire Safe Shutdown Review and Preparation Process and Design Change Process, Revision 5.

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. Other documents reviewed are listed in the Attachment to this report.
  • Unit 1 casing cooling pump house
  • Unit 1 and 2 fuel oil pump house
  • Unit 1 quench spray pump house

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Resident Inspector Quarterly Review

a. Inspection Scope

The inspectors reviewed a licensed operator performance on October 6, 2015, during a simulator scenario which involved a failure of charging pumps, loss of bearing cooling pumps, and a leak which led to a small break loss of coolant accident and entry into Emergency Action Level SU6.1, Notification of Unusual Event. The scenario required classifications and notifications that were counted for NRC performance indicator input.

The inspectors observed the following elements of crew performance in terms of communications:

(1) ability to take timely and proper actions;
(2) prioritizing, interpreting, and verifying alarms;
(3) correct use and implementation of procedures, including the alarm response procedures;
(4) timely control board operation and manipulation, including high-risk operator actions; and
(5) oversight and direction provided by the shift supervisor, including the ability to identify and implement appropriate TS actions. The inspectors observed the post training critique to determine that weaknesses or improvement areas revealed by the training were captured by the instructor and reviewed with the operators. Documents reviewed are listed in the Attachment to this report.

b. Findings

No findings were identified.

.2 Quarterly Control Room Operator Performance Observations

a. Inspection Scope

During the inspection period, the inspectors conducted five observations of licensed reactor operators actions and activities to ensure that the activities were consistent with the licensee procedures and regulatory requirements. These observations took place during both normal and off-normal plant working hours. As part of this assessment, the inspectors observed the following elements of operator performance:

(1) operator compliance and use of plant procedures including technical specifications;
(2) control board/in-plant component manipulations;
(3) use and interpretation of plant instruments, indicators and alarms;
(4) documentation of activities;
(5) management and supervision of activities; and,
(6) communication between crew members.

The inspectors observed and assessed licensed operator performance during the following activities:

  • October 5, 2015, during the 1H EDG slow start
  • October 8, 2015, during maintenance on Ladysmith 230kV offsite power line
  • October 10, 2015, during the 2J EDG slow start
  • October 12, 2015, during the 2B safety injection pump PT

b. Findings

No findings were identified.

.3 Licensed Operator Requalification

a. Inspection Scope

Annual Review of Licensee Requalification Examination Results: On February 13, 2015, the licensee completed the comprehensive biennial requalification written examinations and the annual requalification operating examinations required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2), Requalification Requirements, of the NRCs Operators Licenses. The inspectors performed an in-office review of the overall pass/fail results of the individual operating examinations and the crew simulator operating examinations in accordance with Inspection Procedure (IP) 71111.11, Licensed Operator Requalification Program.

These results were compared to the thresholds established in Section 3.02, Requalification Examination Results, of IP 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

For the three equipment issues listed below, the inspectors evaluated the effectiveness of the respective licensee's preventive and corrective maintenance. The inspectors performed walkdowns of the accessible portions of the systems, performed in-office reviews of procedures and evaluations, and held discussions with 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 6. Other documents reviewed are listed in the Attachment to this report.

  • CR1002368, CR1010444, CR1010424, Service water valve foreign material

b. Findings

Introduction:

A self-revealing, Green NCV of TS 5.4.1.a, "Procedures," as required by Regulatory Guide 1.33, Revision 2, Appendix A, Section 9a, Procedures for Performing Maintenance was identified for inadequate implementation of licensee procedure MA-AA-102, Attachment 4, "Foreign Material Exclusion," Part D Closeout Inspections Revision 15, which resulted in foreign material intrusion into the B SW return header.

Specifically, the inadequate FME closeout led to foreign material intrusion into the B SW return header when maintenance materials like plastic bags and mop heads were not removed and made their way into the B SW return header.

Description:

On June 22, 2015, the licensee began removal of the 'B' SW return header for a planned maintenance. During the work activity, the area was controlled as a Standard FME level which eliminates the requirement for all equipment and materials to be logged in and out of the piping, based on the performance of a complete closeout inspection of the involved area, the licensee observed that two return header valves did not seat and were leaking by as observed at the spray array. The licensee complied with TS 3.7.8 by locking open and de-energizing the two leaking valves. This ensured that the valves were in their required safety position for a design basis accident. On September 21, 2015, the licensee reopened the B SW return header for maintenance and discovered that maintenance materials such as plastic bags and mop heads were not removed prior to the FME closeout in June 2015. The mop heads were preventing two return header valves from seating properly. The licensee implemented an FME recovery plan and returned the 'B' SW return header to service.

Analysis:

The inspectors identified a PD for the failure to adequately implement the foreign material exclusion maintenance procedure MA-AA-102, Attachment 4, "Foreign Material Exclusion," Part D Closeout Inspections Revision 15. The inspectors determined that the finding was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstone objective to ensure the availability of systems that respond to initiating events to prevent undesirable consequences, (i.e., core damage). Specifically, the inadequate FME closeout led to foreign material intrusion into the B SW return header when maintenance materials like plastic bags and mop heads were not removed and made its way into the B SW return header. Using Manual Chapter 0609.04, Initial Characterization of Findings, dated June 19, 2012, the finding was determined to affect the Mitigating Systems Cornerstone. The inspectors screened the finding using IMC 0609, Appendix A, Significance Determination Process (SDP) for Findings at-Power, dated June 19, 2012, and determined that it screened as Green because the finding did not affect the design or qualification of the SW system and it did not represent a loss of system safety function. The finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Management component, because the licensee did not follow procedure requirements of MA-AA-102, Attachment 4, "Foreign Material Exclusion," Part D Closeout Inspections Revision 15 during the return to service portion of the work activity for the B SW return header. [H.5]

Enforcement:

TS 5.4.1.requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A. Section 9a of Appendix A requires procedures for performing maintenance including "preventive and corrective maintenance operations which could have an effect on the safety of the reactor." The licensee established procedure MA-AA-102, Revision 15, to meet the Regulatory Guide 1.33 requirement. Attachment 4, "Foreign Material Exclusion, Part D Closeout Inspections was developed to ensure equipment was restored properly following maintenance. Contrary to the above, during the closeout on June 16, 2015, the licensee did not ensure that Part D Closeout Inspections was fully implemented during the return to service portion of the SW work activity. Specifically, the inadequate FME closeout led to foreign material, such as plastic bags and mop heads, intrusion into the B SW return header adversely impacting safety-related equipment. The licensee entered this condition into its corrective action program as CR1010424. The licensee restored compliance by removing the FME, conducting a "stand down," reinforcing the standards and requirements for FME controls and general procedural compliance, as well as reinforcing expectations for the attention to detail of work practices. Because this finding is of very low safety significance and the licensee has entered it into their corrective action program (CR1010424), this violation is being treated as an NCV, consistent with the NRC Enforcement Policy. (NCV 05000338, 339/2015004-01: Failure to Follow Foreign Material Exclusion Procedure)

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

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

(1) effectiveness of the risk assessments performed before maintenance activities were conducted;
(2) management of risk;
(3) appropriate and necessary steps taken to plan and control the resulting emergent work activities upon identification of an unforeseen situation; and,
(4) adequate identification and resolution of maintenance risk assessments and emergent work problems. 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. The inspectors reviewed the corrective action program to verify that deficiencies in risk assessments were being identified and properly resolved.
  • 1H EDG exhaust leakage during surveillance on November 3, 2015
  • Work week activities for the week of November 16, 2015 and 1J EDG standby jacket pump seal leakage on November 20, 2015
  • 2H EDG fuel oil tank flushing due to elevated particulates on November 30, 2015

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

.1 Operability and Functionality Review

a. Inspection Scope

The inspectors reviewed three operability determinations and functionality assessments, 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 compensatory measures;
(4) whether the compensatory measures, if involved, were in place, would work as intended, and were appropriately controlled; and
(5) where continued operability was considered unjustified, the impact on TS Limiting Conditions for Operation and the risk significance in accordance with the SDP. The inspectors review included a verification that operability determinations (OD) were made as specified by procedure OP-AA-102, Operability Determination, Revision 13. Other documents reviewed are listed in the Attachment to this report.
  • CA3010182, SW spray array piping
  • CR1016789, 1H EDG small candle fire
  • CR1020210, Unit 1 C charging pump coupling guard

b. Findings

No findings were identified.

1R18 Plant Modifications

Permanent Modifications

a. Inspection Scope

The inspectors reviewed one permanent plant modification design change packages listed below. The inspectors conducted a walkdown of the installation, discussed the desired improvement with system engineers, and reviewed the 10 CFR 50.59 Safety Review/Regulatory Screening, technical drawings, test plans and the modification package to assess the TS implications. Other documents reviewed are listed in the to this report.

  • DC-NA-15-00085, EDG Fuel Oil Transfer Pump Equivalent Replacement

b. Findings

No findings were identified.

1R19 Post Maintenance Testing

a. Inspection Scope

The inspectors reviewed three post maintenance test procedures and/or test activities, listed below, for selected risk-significant mitigating systems to assess whether:

(1) the effect of testing on the plant had been adequately addressed by control room and/or engineering personnel;
(2) testing was adequate for the maintenance performed; (3)acceptance criteria were clear and adequately demonstrated operational readiness consistent with design and licensing basis documents;
(4) test instrumentation had current calibrations, range, and accuracy consistent with the application;
(5) 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 14.
  • 2-PT-89.1A, Fuel Oil Sampling - Diesel Day Tank 2-EG-TK-2H, Revision 13

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

For the four 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 Test:

  • 2-PT-71.2Q.1 2-FW-P-3A, A Motor-Driven AFW IST Comprehensive Pump and Valve Test, Revision 12 Other Surveillance Tests:
  • 1-PT-46.3A, Primary-To-Secondary Leakrate Determination, Revision 15
  • 2-PT-36.5.3A, Solid State Protection System Output Slave Relay Test (Train A),

Revision 37

b. Findings

No findings were identified.

1EP6 Drill Evaluation Emergency Preparedness Drill

a. Inspection Scope

On October 6, 2015, the inspectors reviewed and observed the performance of a drill that involved an Alert with a small break loss of coolant accident leading to failed fuel.

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 performance critique. Exercise issues were captured by the licensee in their corrective action program as CRs. Requalification training deficiencies were captured within the operator training program.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Barrier Integrity, Emergency Preparedness, Public Radiation Safety, and Occupational Radiation Safety

4OA1 Performance Indicator (PI) Verification

Mitigating Systems PIs

a. Inspection Scope

The inspectors performed a periodic review of the Unit 1 and Unit 2 PIs listed below to assess the accuracy and completeness of the submitted data, and whether the performance indicators were calculated in accordance with the guidance contained in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. 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 October 1, 2014 through September 30, 2015. Documents reviewed included applicable NRC inspection reports, licensee event reports, operator logs, station performance indicators, and related CRs.

  • Safety System Functional Failures

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Review of Items Entered into the Corrective Action Program

As required by NRC 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 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensees corrective action program 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 corrective 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 July through December 2015, 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. Trends noted by the inspectors were previously identified by the licensee and addressed in their corrective action program.

b. Assessment and Observations No findings were identified. In general, the licensee has identified trends and has addressed the trends with their corrective action program.

.3 Annual Sample: Review of CR1010424, Foreign Material Found Inside SW Spray Array

Isolation Valve

a. Inspection Scope

The inspectors performed a review regarding the licensees assessments and corrective actions CR1010424, Foreign Material Found Inside SW Spray Array Isolation Valve 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 CAs against the requirements of the licensees CAP as specified in licensee procedure, PI-AA-200, Corrective Action Program, Revision 28 and 10 CFR 50, Appendix B.

b. Findings and Observations

Findings are discussed in Section 1R12. In general, the inspectors verified that the licensee had identified problems at an appropriate threshold and entered them into the CAP database, and had proposed or implemented appropriate corrective actions.

4OA3 Event Followup

(Closed) Licensee Event Report (LER) 05000339/2015-001-00: Emergency Switchgear Outside Design Analysis for High Energy Line Break Due to an Unlatched Door On October 7, 2015, the licensee discovered that for Unit 2 a high energy line break (HELB) door between Unit 1 turbine building and the safety-related Unit 2 emergency switchgear (ESGR) was slightly open and unlatched. The door was immediately latched and closed. The licensee was required to make an 8-hour Non-Emergency report to the NRC. This report was not made until October 8, 2015, at approximately 1823 hours0.0211 days <br />0.506 hours <br />0.00301 weeks <br />6.936515e-4 months <br />, when the Unit 2 ESGR was determined to be outside of the design analysis for a Unit 1 HELB. Documents reviewed are listed in the Attachment to this report. This is a licensee identified violation and the corrective actions are discussed in Section 4OA7.

This issue was entered into the licensees CAP as CR1012468.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On January 25, 2016, the resident inspectors presented the inspection results to Mr. G.

Bischof and other members of the staff, who acknowledged the findings. The inspectors verified no proprietary information was retained by the inspectors or documented in this report.

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) or Severity Level IV were identified by the licensee and are violations of NRC requirements which meet the criteria of the NRC Enforcement Policy, for being dispositioned as Non-Cited Violations.

  • NUREG 1022, Event Reporting Guidelines 50.72 and 50.73, Revision 3, section 3.2.4 and 3.2.7, cover degraded or unanalyzed conditions and an event or condition where structures, components, or trains of a safety system could have failed to perform their intended safety function as described in the plant safety analysis.

Contrary to this, on October 7, 2015, the licensee failed to ensure the ESGR door was fully latched. As a result, when security personnel conducted their periodic rounds, the ESGR door, a HELB boundary, was determined to not be fully latched for approximately 46 minutes. The night shift operating crew failed to review the reportability for a HELB boundary not being met. The dayshift operating crew made the required 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> report to the NRC Headquarters Operations Center at 1823 on October 8, 2015. The inspectors determined that the failure to submit a report required by 10 CFR 50.72 for the unanalyzed condition described above had the potential to impact the regulatory process based, in part, on the information that 10 CFR 50.72 reporting serves. Since the issue impacted the regulatory process, it was dispositioned through the Traditional Enforcement process. The inspectors determined that this issue was a Severity Level IV violation based on Example 6.9.d.9 in the NRC Enforcement Policy. Example 6.9.d.9 specifically states, A licensee fails to make a report required by 10 CFR 50.72 or 10 CFR 50.73. This issue was entered into the licensees CAP as CR1012468.

  • Procedure CM-AA-FPA-100, Fire Protection/Appendix R (Fire Safe Shutdown)

Program, Revision 10, Attachment 2, Section 3.12, step n.1 states, Fire doors must be closed and latched at all times. Contrary to Section 3.12, step n.1 of CM-AA-FPA-100, the licensee failed to ensure the fire door to the ESGR was closed and latched at all times. Specifically, on October 7, 2015, when security personnel conducted their periodic round, the ESGR door, a fire boundary, was found to not be fully latched. The ESGR door, a HELB boundary, was determined to not be fully latched for approximately 46 minutes. This finding was identified by the license and entered in the licensees corrective action program as CR1012468. The inspectors performed a significance determination using NRC Inspection Manual 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 1 dated July 1, 2012. Because the Transient Initiator was a HELB that would impact both trains of mitigation equipment required to transition the plant to a stable shutdown condition, a detailed risk evaluation was required. A bounding risk evaluation was performed by a regional SRA which assumed that all pipe failures in turbine building high energy lines with enough energy to create a harsh environment would lead to failure of all equipment within the ESGR and result in a conditional core damage probability of 1.0. The systems considered were main steam, main steam drain, auxiliary steam, extraction steam, low pressure steam, blowdown, feedpump discharge and feedpump recirculation piping. Pipe mean failure rate data from EPRI report 102186 was used. No isolation of the pipe ruptures were assumed and no credit was allowed for operations to realize that a HELB had occurred and for closing the door. An exposure period of 46 minutes was utilized. The phase 3 SDP risk assessment determined the risk of the performance deficiency was an increase in core damage frequency of <1E-6, very low safety significance (Green). The short exposure period mitigated the risk of the performance deficiency.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

M. Becker, Manager, Nuclear Outage and Planning
G. Bischof, Site Vice President
R. Evans, Radiation Protection and Chemistry Manager
B. Gaspar, Manager, Nuclear Site Services
R. Hanson, Manager, Nuclear Protection Services
E. Hendrixson, Director, Nuclear Site Engineering
L. Hilbert, Director, Nuclear Station Safety & Licensing
M. Hofmann, Site Supervisor Emergency Preparedness
J. Jenkins, Manager, Nuclear Maintenance
P. Kemp, Supervisor, Station Licensing
J. Leberstien, Technical Consultant, Licensing
F. Mladen, Plant Manager
J. Plossl, Supervisor, Nuclear Station Procedures
J. Schleser, Manager, Nuclear Organizational Effectiveness
G. Simmons, Supervisor Health Physics Operations
J. Slattery, Manager, Nuclear Operations
W. Standley, Manager, Nuclear Training
N. Turner, Corporate Manager Emergency Preparedness
M. Whalen, Technical Advisor, Licensing

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Open and

Closed

05000338,339/2015-01 NCV Failure to Follow Foreign Material Exclusion Procedure (Section 1R12)

Closed

05000339/2015-002 LER Emergency Switchgear Outside Design Analysis for High Energy Line Break Due to an Unlatched Door (Section 4OA3.1)

LIST OF DOCUMENTS REVIEWED

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