IR 05000338/2019011
| ML19350B977 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 12/16/2019 |
| From: | Bradley B NRC/RGN-II/DRP/RPB4 |
| To: | Stoddard D Virginia Electric & Power Co (VEPCO) |
| P. Niebaum, RII/DRP | |
| References | |
| IR 2019011 | |
| Download: ML19350B977 (20) | |
Text
December 16, 2019
SUBJECT:
NORTH ANNA POWER STATION, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000338/2019011 AND 05000339/2019011
Dear Mr. Stoddard:
On November 7, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your North Anna Power Station, Units 1 and 2. On November 7, 2019 the NRC inspectors discussed the results of this inspection with Mr. Jim Jenkins and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available. No NRC-identified or self-revealing findings were identified during this inspection.
A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV)
consistent with Section 2.3.2 of the Enforcement Policy.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Bradley J. Davis, Chief Reactor Projects Branch 4 Division of Reactor Projects
Docket Nos. 05000338 and 05000339 License Nos. NPF-4 and NPF-7
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000338 and 05000339
License Numbers:
Report Numbers:
05000338/2019011 and 05000339/2019011
Enterprise Identifier:
I-2019-011-0030
Licensee:
Virginia Electric and Power Company
Facility:
North Anna Power Station, Units 1 and 2
Location:
Mineral, VA
Inspection Dates:
October 21, 2019 to November 08, 2019
Inspectors:
A. Beasten, Resident Inspector (Team Leader)
G. Eatmon, Resident Inspector
P. Niebaum, Senior Project Engineer
J. Steward, Resident Inspector
Approved By:
Bradley J. Davis, Chief
Reactor Projects Branch 4
Division of Reactor Projects
Commented [EG1]: Does the TL get identified?
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at North Anna Power Station, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. A licensee-identified non-cited violation is documented in report section: 71152
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
Commented [EG2]: what about the LIV?
Commented [NP3R2]: Not reqd per IMC 0611
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems.
- Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Corrective Action Program Assessment: Based on the samples reviewed, the team determined that the licensees corrective action program (CAP) complied with regulatory requirements and self-imposed standards. The licensees implementation of the CAP adequately supported nuclear safety.
Effectiveness of Problem Identification: The inspectors determined that the licensee was effective in identifying problems and entering them into the CAP at the appropriate threshold. This conclusion was based on a review of the requirements for initiating condition reports (CRs) as described in licensee procedure PI-AA-200, "Corrective Action Program,"
and the site's management expectation that employees were encouraged to initiate condition reports. Additionally, site management was actively involved in the corrective action program and focused appropriate attention on significant plant issues. The inspectors performed walk downs, reviewed CRs, and reviewed system health trending for Diesel Generators and emergency AC power, the Service Water System, and the Low Head Safety Injection System. Based on the inspectors' reviews and walk downs of accessible portions of those systems, the inspectors determined that deficiencies were being identified and placed in the CAP.
Effectiveness of Problem Prioritization and Evaluation: Based on the review of CRs sampled by the inspection team during the onsite period, the inspectors concluded that problems were prioritized and evaluated in accordance with the CAP requirements described in procedure PI-AA-200. The inspectors determined that adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that plant personnel had generally conducted cause evaluations in compliance with the licensees CAP procedures, including appropriate cause determinations, and performed adequate levels of analysis based on the significance of the issues being evaluated.
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 corrective actions were effective, timely, and commensurate with the safety significance of the issues. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence. The inspectors reviewed performance indicators, CRs, and effectiveness reviews, as applicable, to verify that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to preclude repetition (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.
Assessment 71152B Operating Experience, Self-Assessments, and Audits: The inspectors examined the licensee's program for obtaining and using industry operating experience. This included a review of procedure PI-AA-100-1007, "Operating Experience Program," selected corrective action program action requests, and the licensees operating experience (OE) database to assess the effectiveness of how external and internal OE data was evaluated at the plant. Additionally, the inspectors selected OE documents such as NRC generic communications, licensee event reports, vendor notifications, and plant internal OE items which had been issued since July 2017 to verify that the licensee had appropriately evaluated each notification for applicability to the station, and whether issues identified through these reviews were entered into the CAP.
The inspectors determined that the scopes of assessments and audits were adequate. Self-assessments were generally detailed and critical. The inspectors verified that condition reports (CRs) were created to document areas for improvement and findings resulting from self-assessments and verified that actions had been completed consistent with those recommendations. Audits of the quality assurance program appropriately assessed performance and identified areas for improvement. Generally, the licensee performed evaluations that were technically accurate.
The inspectors determined that the station's processes for the use of industry and NRC operating experience information and for the performance of audits and self assessments were effective and complied with all regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The inspectors concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented to address lessons learned as needed. The inspectors determined that the licensee was effective at performing self-assessments and audits to identify issues at a low level, properly evaluated those issues, and resolved them commensurate with their safety significance.
Assessment 71152B Safety Conscious Work Environment: Based on a sample of 25 individuals interviewed from a cross-section of plant employees, the inspectors found no evidence of challenges to the safety conscious work environment. Employees interviewed appeared knowledgeable of avenues to raise safety concerns and appeared willing to raise nuclear safety concerns through at least one of the several means available.
Licensee-Identified Non-Cited Violation 71152B This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: North Anna Technical Specifications 5.4, Procedures, paragraph 5.4.1 required in part that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Regulatory Guide (RG) 1.33, Rev. 2, Appendix A, dated February 1978. RG 1.33, Quality Assurance Program Requirements (Operations),
Rev. 2, Appendix A, section 9.b required in part that preventive maintenance schedules should be developed to specify inspections of equipment. Licensee Procedure 0-MPM-1207-04, Annual Pumping of Security and Electrical Cable Vaults, Rev. 10, implemented this requirement for certain safety related (SR) medium voltage cables. Contrary to the above, the licensee failed to inspect (SR) medium voltage cables susceptible to water submergence in accordance with this procedure. Licensee procedure 0-MPM-1207-04 required annual pumping and inspections of SR medium voltage cables susceptible to submergence to prevent long term submergence of electrical cables which could lead to cable degradation. According to the licensee, the annual inspections have not occurred since 2016.
Significance/Severity: Green. This violation was screened to Green, very low safety significance in accordance with IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions because all of the screening questions were answered No.
Corrective Action References: This issue was documented in the licensees corrective action program (CAP) as condition report (CR) 1133235.
Minor Violation 71152B Minor Violation: The NRC identified a minor violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to ensure that instructions, procedures, or drawings were appropriate for the circumstances. Specifically, the licensee failed to ensure that maintenance procedure 0-MPM-0452-18, Visual Inspection of Damper for Condition of External Duct Work, Operator, Hardware and Operation, and the model preventive maintenance (PM) work orders (WO) included adequate instructions for inspection of the Control Room and Emergency Switchgear Air Handlers.
Following a failure of the main control room chiller fan discharge damper to open when the fan was started, the licensee revised maintenance procedure 0-MPM-0452-18 to include instructions for mechanical inspection of the damper linkages. The inspectors reviewed the maintenance procedure and observed that the Note added prior to step 6.2.3 in the procedure failed to direct action to use a wrench to test for tightness.
Screening: The inspectors determined the performance deficiency was minor. The performance deficiency was screened in accordance with Inspection Manual Chapter 0612 Appendix B. The inspectors determined the performance deficiency was minor because no subsequent failures of the main control room chiller discharge dampers have occurred. This issue was captured in CR 11135344.
Enforcement:
This failure to comply with 10 CFR 50, Appendix B, Criterion V constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On November 7, 2019, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Jim Jenkins and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71152B
Calculations
CT-EQUAL-000-
GQE-06.02-G01
71152B
Calculations
NA-EQUAL-000-
PQE-06.02-P01
71152B
Corrective Action
Documents
ACE 013252
ACE 3066417
ACE 3070837
ACE 3056632
ACE 3084650
ACE 3151216
Apparent Cause Evaluation
71152B
Corrective Action
Documents
CA 3031034
CA 3049131
CA 3056633
CA 3065939
CA 3069003
CA 3070099
CA 3070100
CA 3070231
CA 3070232
CA 3075045
CA 3075050
CA 3151215
CA 3154355
CA 3166734
CA 3166959
CA 3168772
CA 3168774
CA 7298545
CA 7310582
CA 7312500
CA 7374628
CA 7376776
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CA 7395457
CA 7433019
CA 7459183
CA 7474370
CA 7482599
CA 7482608
CA 7486588
CA 7488252
CA 7488254
CA 7492892
CA 7498661
CA 7510589
CA 7512926
CA 7517194
CA 7517205
CA 7517219
CA 7517220
CA 7517221
CA 7518983
CA 7519648
CA 7520768
CA 7525374
CA 7584424
CA 7587968
CA 7593188
CA 7605944
CA 7608868
CA 7610872
CA 7616221
CA 7631022
CA 7631762
CA 7631763
CA 7639127
CA 7642350
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CA 7646744
CA 7649215
CA 7656339
CA 7658212
CA 7660850
CA 7671240
CA 7695557
CA 7695558
71152B
Corrective Action
Documents
CR 1113558
CR 1119927
CR 1129587
CR 1131745
Part 21 Evaluations
71152B
Corrective Action
Documents
CR 525801
CR 549139
CR 577960
CR 1001891
CR 1036687
CR 1036795
CR 1052292
CR 1056554
CR 1057223
CR 1057418
CR 1058722
CR 1062578
CR 1062579
CR 1066949
CR 1073360
CR 1076695
CR 1078223
CR 1078405
CR 1078504
CR 1078722
CR 1079201
CR 1079241
Commented [SJ4]: Evaluations is not spelled correctly
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR 1079363
CR 1082177
CR 1083343
CR 1083517
CR 1083602
CR 1083620
CR 1083636
CR 1083803
CR 1084460
CR 1084876
CR 1085033
CR 1085065
CR 1087430
CR 1089154
CR 1089699
CR 1091753
CR 1091778
CR 1092314
CR 1093119
CR 1093692
CR 1093769
CR 1097015
CR 1097201
CR 1097721
CR 1097753
CR 1098252
CR 1098808
CR 1098816
CR 1099558
CR 1103503
CR 1103691
CR 1103698
CR 1103788
CR 1104560
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR 1109736
CR 1109741
CR 1110081
CR 1113055
CR 1113581
CR 1114435
CR 1114785
CR 1114816
CR 1115132
CR 1116471
CR 1116532
CR 1116553
CR 1117127
CR 1117324
CR 1117941
CR 1119937
CR 1120227
CR 1120570
CR 1120826
CR 1120845
CR 1123419
CR 1123421
CR 1123476
CR 1123701
CR 1123824
CR 1124170
CR 1124871
CR 1124877
CR 1124966
CR 1125173
CR 1125645
CR 1125681
CR 1125934
CR 1126297
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR 1126809
CR 1127060
CR 1127144
CR 1127280
CR 1127555
CR 1127630
CR 1128297
CR 1128633
CR 1128717
CR 1129074
CR 1129857
CR 1130277
CR 1130290
CR 1131509
CR 1131558
CR 1131745
CR 1132414
CR 1132861
CR 119857
71152B
Corrective Action
Documents
DTI-CA-3049490
71152B
Corrective Action
Documents
LEE 7298545
LEE 7315898
LEE 7374629
LEE 7379723
LEE 7419976
LEE 7480479
LEE 7630987
LEE 7646819
LEE 7656340
Level of Effort Evaluation
71152B
Corrective Action
Documents
PIR 1130044
PIR 1116952
PIR 1116837
PIR 1115560
Part 21 evaluations for applicability
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PIR 1112352
PIR 1110540
71152B
Corrective Action
Documents
Resulting from
Inspection
203300380
203300386
203300387
203300388
203300390
203300394
203300395
203300396
203300849
Work Orders
71152B
Corrective Action
Documents
Resulting from
Inspection
CR 1134006
CR 1134008
CR 1134012
CR 1134013
CR 1134014
CR 1134015
CR 1134019
CR 1134020
CR 1134022
CR 1134073
CR 1134083
CR 1134095
CR 1134097
CR 1134100
CR 1134102
CR 1134103
CR 1134104
CR 1134106
CR 1134107
CR 1134108
CR 1134111
CR 1134123
CR 1134125
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR 1134147
CR 1134150
CR 1134443
CR 1134657
CR 1135103
CR 1135106
CR 1135251
CR 1135302
CR 1135339
CR 1135344
71152B
Engineering
Evaluations
ETE-NA-2019-
013
ETE-NA-2018-
011
ETE-NA-2019-
030
ETE-NA-2015-
0054
71152B
Miscellaneous
Service Water System Health Report
Q2-2019
71152B
Miscellaneous
Service Water System Top Issues List
07/08/2019
71152B
Miscellaneous
Safety Injection System Health Report
Q2-2019
71152B
Miscellaneous
1-LOG-6F
Main Control Room Chiller Operating Logs
24
71152B
Miscellaneous
2-AR-K-E1
Annunciator Response Procedure for RWST HI Level
71152B
Miscellaneous
EE007, SW002,
EG002
Service Water System Maintenance Rule Scoping Functions
71152B
Miscellaneous
SDBD-NAPS-SW
Service Water System Design Basis Document
71152B
Miscellaneous
Serial No.17-343
Dominion Energy Letter to the NRC, "Commitments for
Resolution of Anchor Darling Double Disc Gate Valve Part 21
Issues."
August 31,
2017
71152B
Miscellaneous
Serial No. 17-
343A
Dominion Energy Letter to NRC, "Anchor Darling Double
Disc Gate Valve Information and Status."
December
18, 2017
71152B
Miscellaneous
Serial No.18-238
Dominion Energy Letter to the NRC, "Updated Anchor
December
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Darling Double Disc Gate Valve Information and Repair
Status."
19, 2018
71152B
Operability
Evaluations
CA 7355047
Service Water Pump House Missile Vulnerability
08/22/2019
71152B
Procedures
0-GEP-52
Conduct of Post Modification Testing
71152B
Procedures
0-MPM-0452-18
Visual Inspection of Damper for Condition of External Duct
Work, Operator, Hardware and Operation
Revision 4
71152B
Procedures
0-MPM-0806-02
Inspection of Control Room Chillers
71152B
Procedures
Identifying and Addressing Nuclear Safety and Quality
Concerns
71152B
Procedures
ER-AA-MRL-10
71152B
Procedures
ER-AA-MRL-100
Implementing Maintenance Rule
71152B
Procedures
ER-AA-PRS-1001 Plant Health Committee
71152B
Procedures
ER-AA-SYS-1001
System Health Report
71152B
Procedures
71152B
Procedures
Self Evaluation and Trending
71152B
Procedures
Self-Assessments
71152B
Procedures
Operating Experience Program
71152B
Procedures
Corrective Action
71152B
Procedures
Cause Evaluation
71152B
Procedures
Emergent Issue Response
71152B
Procedures
Root Cause Evaluation
71152B
Procedures
Cause Evaluation Methods
71152B
Procedures
Equipment Apparent Cause Evaluation
71152B
Procedures
Level of Effort Evaluation
71152B
Procedures
Record Creation, Transmittal, and Retrieval
71152B
Self-Assessments
Maintenance Dept Self Evaluation
July 2019
71152B
Self-Assessments
Emergency Plan Department Self Evaluation Monthly Report
August 2019
71152B
Self-Assessments Audit 17-05
Corrective Action, Independent Review and License
Commitments
08/10/2017
71152B
Self-Assessments Audit 17-07
Inservice Inspection, Inservice Testing and Appendix J
71152B
Self-Assessments Audit 17-09
Nuclear Fuel Management and Procurement and MPS
Refueling
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71152B
Self-Assessments Audit 17-10
Offsite Dose Calculation Manual/Radiological Environmental
Monitoring Program/Environmental Protection Plan
2/08/2018
71152B
Self-Assessments Audit 18-02
04/16/2018
71152B
Self-Assessments Audit 18-04
Radiological Protection, Process Control Program, and
Chemistry
07/10/2018
71152B
Self-Assessments Audit 18-05
Design Control and Engineering Programs
71152B
Self-Assessments Audit 18-06
Materials and Procurement
09/20/2018
71152B
Self-Assessments Audit 18-07
Document Control, Records, & Procedures
10/31/2018
71152B
Self-Assessments Audit 19-02
04/17/2019
71152B
Self-Assessments Audit 19-04
Fire Protection, QA Program Implementation and MPS
Refueling
71152B
Self-Assessments Audit 19-05
Corrective Action, Independent Review, and License
Commitments
07/22/2019
71152B
Work Orders
203285593
59080637301
59102472901
59102738867
59102744173
59102776679
59102880719
59103139979
59103140339
203130034
203131880
203140912
203268300
203269312
203275983
203285346
203285591
203290138
203291616
203292714
59403012702
Commented [SJ5]: Implementation is not spelled
correctly
Commented [SJ6]: Commitments is not spelled
correctly
17