IR 05000338/2021001
| ML21131A116 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/11/2021 |
| From: | Stewart Bailey NRC/RGN-II |
| To: | Stoddard D Virginia Electric & Power Co (VEPCO) |
| References | |
| IR 2021001 | |
| Download: ML21131A116 (26) | |
Text
May 11, 2021
SUBJECT:
NORTH ANNA POWER STATION - INTEGRATED INSPECTION REPORT 05000338/2021001 AND 05000339/2021001
Dear Mr. Stoddard:
On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at North Anna Power Station. On April 7, 2021, the NRC inspectors discussed the results of this inspection with Mr. Fred Mladen and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at 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 the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at North Anna Power Station. 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/
Stewart N. Bailey, 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:
05000338/2021001 and 05000339/2021001
Enterprise Identifier: I-2021-001-0075
Licensee:
Virginia Electric & Power Co.
Facility:
North Anna Power Station
Location:
Mineral, VA
Inspection Dates:
January 01, 2021 to March 31, 2021
Inspectors:
M. Tobin, Senior Resident Inspector
K. Carrington, Resident Inspector
M. Thomas, Senior Resident Inspector (Acting)
B. Towne, Resident Inspector, Surry
J. Diaz-Velez, Senior Health Physicist
B. Kellner, Senior Health Physicist
D. Jackson, Senior Project Engineer
P. Niebaum, Senior Project Engineer
Approved By:
Stewart N. Bailey, Chief
Reactor Projects Branch 4
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at North Anna Power Station, 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.
List of Findings and Violations
Failure to identify surveillance test discrepancies associated with the 1J and 2J emergency diesel generators (EDGs).
Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000338,05000339/2021001-01 Open/Closed
[H.12] - Avoid Complacency 71152 The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50, Appendix B,
Criterion XI, Test Control, for the licensees failure to identify surveillance test discrepancies associated with the 1J and 2J emergency diesel generators (EDGs). As a result, the EDGs were declared inoperable and retested using revised procedures before they were returned to an operable status.
Failure to Implement Locking and Tagging Controls Which Impacted the 125 VDC System Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000338,05000339/2021001-02 Open/Closed
[H.11] -
Challenge the Unknown 71152 A self-revealing finding of very low safety significance (Green) with an associated non-cited violation (NCV) of Technical Specifications 5.4.1a, Procedures, was identified for the licensees failure to properly plan and perform maintenance that can affect the performance of safety-related equipment in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances in accordance with Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation). Specifically, while performing work on the B reserve service station transformer (RSST), the licensee failed to ensure adequate locking and tagging controls were in place prior to landing leads and energizing a 125-voltage direct-current (VDC) circuit which resulted in voltage fluctuations within the safety-related DC system.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period at rated thermal power. On February 20, 2021, the unit began coasting down in power for their planned refueling outage. The unit was shut down for a planned refueling outage on March 13, 2021, and remained shut down for the remainder of the inspection period.
Unit 2 operated at or near rated thermal power for the entire inspection period.
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.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the Coronavirus Disease 2019 (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather; extreme cold weather during week of January 31 and February 7, 2021.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 2 high head charging system during 2C charging pump maintenance week of January 19, 2021.
- (2) Unit 1 turbine driven auxiliary feedwater system on January 26, 2021.
(3)1J emergency diesel generator when the 1H emergency diesel generator was tagged out of service on February 12, 2021.
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the residual heat removal system on March 30, 2021.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
(1)2H emergency diesel generator room on February 24, 2021
- (2) Unit 2 cable vault and tunnel on March 19, 2021 (3)service water pump house on March 10, 2021 (4)auxiliary building elevation 244' on March 3, 2021 (5)control room on March 5, 2021
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill on January 19, 2021.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during Unit 1 refueling outage shutdown during the week of March 14, 2021.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator annual requalification operating tests in the simulator on January 26, 2021.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
(1)1-CH-P-1B, 1B Charging Pump, (a)(1) evaluation because unavailability (UA) hours performance criteria exceeded on March 12, 2021.
- (2) Periodic evaluation of maintenance rule program 50.65(a)(3) on March 4, 2021.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (7 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Maintenance risk assessment week of February 8, 2020, when the 1H emergency diesel generator was tagged out of service on February 12, 2021.
- (2) Maintenance risk assessment on February 16, 2021, during swap from Unit 2 'C' to 'B' feedwater pump and winter weather advisory (icing) on February 18, 2021.
- (3) Risk associated with RCS draindown for vessel head removal on March 16, 2021.
- (4) Risk associated with heavy lift of the high-pressure turbine enclosure on March 10, 2021.
- (5) Maintenance risk assessment on March 11, 2021, with the 2H emergency diesel generator inoperable due to emergent issues on March 15, 2021.
- (6) Unplanned shutdown risk change associated with Unit 1 hot leg recirculating valves 1-SI-MOV-1869B and 1-SI-MOV-1890B inoperability on March 25, 2021.
- (7) Shut down Risk associated with Unit 1 transition from Mode 5 to Mode 4 on March 14, 2021.
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) CR1163149 - 2H emergency diesel generator tripped due to faulty lamp socket on February 24, 2021.
- (2) CR1161726 - 2-CC-P-1B exceeded its [inservice testing] vibration alert limit on February 25, 2021.
- (3) CR1162043 - 1-SW-115B motor operated valve body erosion on March 31, 2021.
- (4) CR1168702-1-EG-LI-100A 2A underground storage tank level spurious indication; CR1168144-1-EG-LI-100A inaccurate indication while filling on March 29, 2021.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post-maintenance test (PMT) activities to verify system operability and functionality:
- (1) Work Order (WO) 59203313795 PMT following 1J fuel oil transfer pump relief valve maintenance, on January 20, 2021.
- (2) Unit 2 125 VDC battery charger (2-BY-BC-2-III) PMT on January 21, 2021, following replacement, on January 25, 2021.
- (3) WO 59203351320 - 2H emergency diesel generator PMT following replacement of a shorted lamp socket that caused an unexpected emergency diesel generator trip, on February 17, 2021.
- (4) WO 59103097686 - U1 'A' charging pump speed increaser replacement on February 25, 2021.
- (5) Unit 2 'H' emergency diesel generator PMT following output breaker replacement and troubleshooting on March 22, 2021.
- (6) WO 59203326270- Unit 2 component cooling water pump 1B PMT following overhaul and shaft replacement on March 29, 2021.
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Partial)
(1)
(Partial) The inspectors evaluated refueling outage 1R28 activities from March 13, 2021, to March 31, 2021.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) WO 59203312155 - 1-PT-82H - 1H emergency diesel generator test on January 6, 2021.
(2)2-PT-71.2Q-Unit 2 A motor-driven auxiliary feedwater pump and valve test, on January 28, 2021.
(3)2-PT-33.13 and 2-PT-33.14-Unit 2 RCP bus undervoltage/underfrequency surveillance tests, on January 20, 2021.
(4)1-PT-57.1B-Unit 1 SI pump B surveillance test, on February 17, 2021.
(5)1-PT-36.5.3B-Train 'B' solid state protection system output slave relay test, on February 17, 2021.
Inservice Testing (IP Section 03.01) (2 Samples)
- (1) WO 59203311288 - 2-PT-71.1Q - Unit 2 steam driven auxiliary feedwater pump quarterly test on January 5, 2021.
- (2) WO 59203312126 - 1-PT-71.2Q - Unit 1 A motor driven auxiliary feedwater pump and valve test on January 7, 2021.
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) B team emergency preparedness drill on February 23,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas.
- (1) The inspectors reviewed the following:
Radiation Work Packages (RWPs)
- 21-3106 - Minor Maintenance in High Radiation Areas (HRAs), Revision 0
- 21-3130 - Walkdowns in HRAs, Revision 0
- 21-3220 - NDE in Locked High Radiation Areas (LHRAs), Revision 0
- 21-3230 - General Walkdown & Inspection, Revision 0
Electronic Alarming Dosimeter Alarms
- Reviewed one valid dose alarm that occurred in February 2021
- Reviewed 14 planned or pre-briefed dose rate alarms that occurred during the inspection period
Labeling of Containers
- Observed labeling and material condition of 10 radioactive material containers located in various locations inside the Protected Area (PA)
- Observed labeling and material condition of 20 radioactive material containers located in various Radioactive Material (RAM) storage locations outside the PA
Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.
- (1) Observed licensee surveys of potentially contaminated material leaving the radiologically controlled area (RCA).
- (2) Observed workers exiting the RCA during the Unit 1 refueling outage.
- (3) Observed workers exiting the Unit 1 containment, removing protective clothing, and monitoring during a refueling outage.
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.
- (1) The inspectors also reviewed the following radiological work package for areas with airborne radioactivity:
- 21-3209 - Install and remove scaffolding during N1 R28, Revision 0
- (2) The inspectors also reviewed the following radiological work package for areas with airborne radioactivity:
- 21-3201 - lncore Drive unit 5 and 10 path unit lubrication, inspection, cleaning, adjustment, and repair, Revision 0
- (3) The inspectors also reviewed the following radiological work package for areas with airborne radioactivity:
- 21-3253 - Work in the Transfer Canal, Revision 0
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) Unit 1 transfer canal upender and track (LHRA)
- (2) Unit 1 and 2 volume control tank rooms (LHRA)
- (3) Unit 1 incore sump access ('keyway') (Very High Radiation Area)
- (4) Unit 1 241 elevation regenerative heat exchanger cubicle (LHRA)
(5)249' elevation fuel building basement - access door to 'demin alley' (LHRA)
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01)
- (1) Inspectors evaluated the licensees performance in controlling, labeling, and securing radioactive materials. Verified inventory and control of the Victoreen CHARMs calibration source (S/N 104).
- (2) Inspectors evaluated the licensees performance in controlling, labeling, and securing radioactive materials. Verified inventory and control of two high activity (Category 2)box calibrator sources (S/Ns 03127GY, and KR-4095).
Radioactive Waste System Walkdown (IP Section 03.02) (1 Sample)
- (1) Inspectors walked down accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality.
Waste Characterization and Classification (IP Section 03.03) (2 Samples)
- (1) The inspectors evaluated the licensees characterization and classification of radioactive waste (Dry Active Waste).
- (2) The inspectors evaluated the licensees characterization and classification of radioactive waste (Spent Resin Holdup Tank).
Shipment Preparation (IP Section 03.04) (2 Samples)
- (1) The inspectors observed that a shipment containing radioactive material was prepared according to requirements.
- Shipment of Unit 1 Pressurizer Safety (Limited Quantity shipment).
Shipment # 21-1013, 3/18/2021
- (2) The inspectors observed completion of the incoming radiological survey and receipt of a shipment containing radioactive material according to requirements.
Shipping Records (IP Section 03.05) (6 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
- (1) Radioactive Material Shipment #19-BCO-05.
- (2) Radioactive Material Shipment #20-BCO-01.
- (3) Radioactive Material Shipment #20-BCO-03.
- (4) Radioactive Material Shipment #19-CWF-01.
- (5) Radioactive Material Shipment #20-BCO-07.
- (6) Radioactive Material Shipment #20-WCS-01
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 03.01)===
- (1) Unit 1 (January 2020 - December 2020)
- (2) Unit 2 (January 2020 - December 2020)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 03.02) (2 Samples)
- (1) Unit 1 (January 2020 - December 2020)
- (2) Unit 2 (January 2020 - December 2020)
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 03.03) (2 Samples)
- (1) Unit 1 (January 2020 - December 2020)
- (2) Unit 2 (January 2020 - December 2020)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 03.15) (1 Sample)
- (1) Units 1 and 2 (July 2020 through February 2021)
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in human performance that might be indicative of a more significant safety issue on February 24, 2021.
Annual Follow-up of Selected Issues (IP Section 02.03) (3 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) CR 1164001 - Follow-up on a 4Q2020 minor violation associated with inadequate procedure on February 10, 2021. The inspectors selected this as a routine minor violation close-out follow-up. The inspectors ensured that the close-out of the minor violation was adequate and ensured that the inadequate procedure associated with the RPV lower internals installation was correctly updated.
- (2) CR 1162157-Landing hot wires for [reserve service station transformer] B cause plant battery issues. The inspectors selected this issue for follow-up based on the increased number of human performance events onsite. The inspectors reviewed the licensee's corrective actions and dispositioning of the event as a Level 1 clearance and tagging event. The inspectors verified the issue was assigned the appropriate significance commensurate with the event. One non-cited violation was identified as documented in the results section of this report.
- (3) CR 1165766 - Electrical work on live system due to personnel not signing on to a tagout on March 31,
INSPECTION RESULTS
Failure to identify surveillance test discrepancies associated with the 1J and 2J emergency diesel generators (EDGs).
Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000338,05000339/2021001-01 Open/Closed
[H.12] - Avoid Complacency 71152 The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XI, Test Control for the licensees failure to identify surveillance test discrepancies associated with the 1J and 2J emergency diesel generators (EDGs). As a result, the EDGs were declared inoperable and retested using revised procedures before they were returned to an operable status.
Description:
On November 13, 2020, the inspectors were provided a copy of surveillance test procedure 2-PT-82.12J, 2J Diesel Generator Isochronous Mode (Start by ESF Actuation),
Rev. 40-OTO1, conducted on October 1, 2020. During the week of November 17, 2020, the inspectors reviewed the information associated with the EDG load reject portion of the test to verify the times documented in the procedure for voltage and frequency to return to steady state values following the load rejection. The inspectors reviewed this procedure because it was used as a post-maintenance test following replacement of the 2J EDG electronic governor.
The data recorder used for this surveillance test, with the data needed to verify the test requirements were satisfied, was stored at another facility within the fleet. Because that data recorder was not readily available that day, the inspectors chose to review load reject data associated with a similar test procedure, 2-PT-83.12J, 2J Diesel Generator Test (Start by ESF Actuation) Followed by 24-Hour Run and Hot Restart Test, which was conducted on September 16, 2020. The inspectors identified discrepancies associated with the documented voltage test results on November 18, 2020. The discrepancies were documented in the licensees corrective action program as Condition Report (CR)1161094. The licensee later determined that the test on September 16, 2020, was performed satisfactorily when signal noise was filtered out using the data recorder. The inspectors noted that use of the test recorder to filter out signal noise was not documented in the test procedure.
As part of the licensees continued review for the issue documented in CR 1161094, the licensee identified a discrepancy associated with the load reject portion of test procedure 2-PT-82.12J conducted on October 1, 2020. Specifically, step 6.24.4.d.2 recorded the time for EDG voltage to return to steady state values following the load rejection as 1.12 seconds. When a more thorough review of the test recorder data was conducted, the actual time was found to be 4.21 seconds. This exceeded the acceptance criteria of less than 3 seconds required by the procedure and surveillance requirement (SR) 3.8.1.9. On November 18, 2020, this was documented as CR 1161080 and the licensee declared the 2J EDG inoperable. The licensee conducted four troubleshooting runs of the 2J EDG on November 18 and 19, 2020. Following the troubleshooting runs, on November 19, 2020, the licensee conducted a one-time-only test using procedure 2-PT-82.12J, verified that the load rejection capability of the 2J EDG was satisfactory, and declared 2J EDG to be operable.
On November 20, 2020, in response to the issues identified with the load reject portion of the surveillance tests associated with 2J EDG, the licensee reviewed surveillance test procedure 1-PT-83.12J for the 1J EDG conducted on September 10, 2019. During this review, it was determined that the kiloVolt-Ampere-Reactive (kVAR) loading of the 1J EDG was recorded as 0 kVAR when step 6.17.2 required a range of 400-500 kVAR. As a result, the licensee declared the 1J EDG inoperable, conducted a one-time only test using procedure 1PT-82.12J at the proper kVAR setting, obtained satisfactory results, and subsequently returned the 1J EDG to operable status on November 20, 2020.
Corrective Actions: The licensee revised the EDG test procedures and reperformed the load rejection portion of the applicable surveillance test procedures. Additionally, on one occasion, the licensee made an adjustment to the data recorder to filter out signal noise to obtain a satisfactory test result.
Corrective Action References: CRs 1161080, 1161094, and 1161213
Performance Assessment:
Performance Deficiency: The failure to initially identify unsatisfactory load rejection test results for the 1J EDG on September 19, 2019 and the 2J EDG following performance of surveillance test procedures 2-PT-83.12J and 2-PT-82.12J conducted on September 16, 2020, and October 1, 2020, respectively, was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, licensee personnel responsible for reviewing and approving the emergency diesel generator load reject surveillance tests failed to identify testing discrepancies. Additionally, this issue was sufficiently similar to example 3.k in the NRCs Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues, issued on December 10, 2020. Specifically, the licensee had to perform additional actions that would continue to demonstrate operability of the 1J and 2J EDGs. For the 2J EDG surveillance conducted on September 16, 2020, the licensee made an adjustment to the data recorder to filter out signal noise to obtain a satisfactory test result. For the 2J EDG surveillance initially conducted on October 1, 2020, the licensee reperformed the load rejection portion of the surveillance test with a lower starting bus voltage. For the 1J EDG surveillance test initially conducted on September 19, 2019, the licensee adjusted kVARs to the correct setting and adjusted the bus voltage before obtaining a satisfactory load reject test.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings at-Power, dated January 1, 2021. The finding was determined to be of very low safety significance, GREEN, because when screened using Exhibit 2, Mitigating Systems Screening Questions, all of the screening questions were answered with No.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. The licensee failed to use appropriate error reduction tools when performing and reviewing EDG surveillance test procedures.
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion XI, Test Control, requires, in part, that testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures; and test results shall be documented and evaluated to assure that the test requirements have been satisfied. Contrary to those requirements, the licensee failed to assure the test requirements were satisfied for the 2J EDG surveillance test conducted with licensee procedure 2-PT-83.12 on September 16, 2020, and for the 2J EDG surveillance test conducted with licensee procedure 2-PT-82.12J on October 1, 2020; and failed to verify testing of the 1J EDG was performed in accordance with surveillance test procedure 1-PT-83.12J on September 10, 2019.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Implement Locking and Tagging Controls Which Impacted the 125 VDC System]
Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events
Green NCV 05000338,05000339/2021001-02 Open/Closed
[H.11] -
Challenge the Unknown 71152 A self-revealing finding of very low safety significance (Green) with an associated non-cited violation (NCV) of Technical Specifications 5.4.1a, Procedures, was identified for the licensees failure to properly plan and perform maintenance that can affect the performance of safety-related equipment in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances in accordance with Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation). Specifically, while performing work on the B reserve service station transformer (RSST), the licensee failed to ensure adequate locking and tagging controls were in place prior to landing leads and energizing a 125-voltage direct-current (VDC) circuit, which resulted in voltage fluctuations within the safety-related DC system.
Description:
On December 9, 2020, while troubleshooting an electronic temperature monitor for the B RSST, a control operations technician discovered wires to three instrument gauges for the B RSST that had not been properly terminated. The technician then solicited assistance from the substation supervisor and requested the support of substation electricians to terminate the wires to these gauges. The work to terminate (land) the wires did not undergo the proper challenge, screening, authorization, or lockout/tagout review prior to commencement. As a result, the work proceeded without ensuring adequate tagout controls were in place for equipment and personnel protection and without the required live-dead-live checks in accordance with licensee procedure OP-AA-201, Lockout.
While wires for the three instrument gauges were being terminated, a breaker was closed in the downstream 125 VDC circuit, energizing the lines where the work was being performed. This resulted in alarms in the main control room and voltage fluctuations on the safety-related 125 VDC system. The control operations technician was immediately contacted by the Unit 1 control room operators and directed to stop work activities. The work was immediately halted, the circuit breaker was manually opened, deenergizing the circuit, and the associated alarms cleared. The licensee documented this issue in its corrective action program as condition report (CR) 1162157.
Corrective Actions: Corrective actions included immediately halting work, deenergizing the 125 VDC circuit by manually opening the associated breaker, restoring equipment to a safe condition, updating station procedures, training personnel, and documenting the issue as a Level 1 clearance and tagging event, i.e. major or severe event where no barriers remained between personnel and hazardous energy warranting a human performance review board and more in-depth corrective actions.
Corrective Action References: CR1162157
Performance Assessment:
Performance Deficiency: The inspectors determined the failure to properly plan and perform maintenance such as landing leads while simultaneously energizing an upstream circuit by ensuring adequate locking and tagging controls were in place in accordance with licensee procedure OP-AA-200 had the potential to affect safety-related 125 VDC equipment and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to preplan maintenance resulted in an unplanned energization of wires in the 125 VDC circuit causing equipment trouble alarms in the main control room and voltage fluctuations on the safety-related 125 VDC system. Absent control room intervention, the fluctuations had the potential to become more extensive (i.e. result in the loss of safety-related 125 VDC equipment).
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance, GREEN, because when screened using Exhibit 1, Initiating Events Screening Questions, all of the screening questions were answered No.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. The inspectors determined the finding had a cross-cutting aspect of H.11, Challenge the Unknown, in the Human Performance area. Specifically, the licensee failed to stop when faced with uncertain conditions or evaluate and manage risks before landing wires associated with the 'B' RSST that were outside the original scope of work.
Enforcement:
Violation: Technical Specification 5.4.1.a, Procedures, requires, in part that written procedures be established, implemented, and maintained covering activities listed in Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, Appendix A, February 1978.
Regulatory Guide 1.33, Appendix A, Section 9a, states, in part, that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures
Licensee Procedure OP-AA-201, Lockout, Revision 6, Section 3.2.7, requires in part, ensuring the tagging boundary is adequate for the work being performed and live-dead-live check is performed before starting ANY work if necessary, for safety.
Contrary to those requirements, on December 9, 2020, the licensee failed to properly preplan and perform maintenance in accordance with written procedures when electricians performed work without the adequate locking and tagging controls in place, which inadvertently energized wires associated with the B RSST and caused voltage fluctuations on safety-related DC equipment.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Semiannual Trend Review - Human Performance Events 71152 Through a review of recent issues documented in the licensees corrective action program, the inspectors were concerned that a negative trend may exist in human performance (HU)that can potentially impact nuclear safety. The inspectors are concerned that if human performance is not improved, subsequent HU events may challenge the station in operating the plant safely. The following examples demonstrate a negative trend in HU events (during the last 6 months):
1. CR1163289 - Scaffold builder received a pinched finger due to a missed
communication between other builders working on same component.
2. CR1163935 - Employee in a company vehicle contacted a stationary parking bollard
in parking lot.
3. CR1164057 - Employee entered a vital area improperly.
4. CR1164370 - Employees began work to clean a strainer that was not protected by a
tagout.
5. CR1165012 - Operator did not leave radiologically controlled area at 80 percent of
the dose alarm which resulted in the employee receiving a dose alarm.
6. CR1165328 - An hourly fire watch was performed 8 minutes late.
7. CR1165576 - Employees found a security door unsecured.
8. CR1165941 - Worker dropped a 20lb wrench 8 foot below grazing the leg of another
worker below.
9. CR1166110 - An outdated revision to a procedure was used by workers instead of
the appropriate active version.
10. CR1166093 - A non-limiting technical requirements manual action was not appropriately logged in the Narrative Logs or the LCO tracking database.
11. CR1165201 - NRC identified administrative discrepancy in a corrective action for updating procedures as a result of the Fall 2020 refueling outage issue with the reactor pressure vessel lower internals.
12. CR1166332 - NRC identified transient combustibles in the 2H emergency diesel generator room without a permit.
13. CR1166446 - Technicians used the wrong data values while rescaling Unit 1 T_ref.
The inspectors note that each of the above identified HU issues did not adversely affect nuclear safety; however, the inspectors believe that a degrading trend in human performance could lead to more safety significant issues. The licensee has addressed each HU event individually, and plans to reinforce standards on site across all groups by conducting sitewide standdowns and increase oversight in the field. The inspectors will continue to monitor this trend.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On April 7, 2021, the inspectors presented the integrated inspection results to Mr. Fred Mladen, Site Vice President and other members of the licensee staff.
- On March 18, 2021, the inspectors presented the radiation protection inspection results to Mr. Fred Mladen, Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
0-GOP-4.2
Extreme Cold Weather Operations
Corrective Action
Documents
CR
1165578
Procedures
1-IPM-XX-MISC-
Verification of Transmitter Valve Lineup
Procedures
1-OP-14A
Valve Checkoff - Residual Heat Removal
Procedures
1-OP-31.2
Steam Generator Auxiliary Feedwater System
Procedures
1-OP-31.2A
Valve Checkoff - Auxiliary Feedwater
Procedures
1-OP-6.2
Operation of No. 1J Emergency Diesel Generator from
Control Room
Procedures
1-OP-6.2A
Valve Checkoff - 1J Diesel Engine Cooling Water
Procedures
1-OP-6.4A
Valve Checkoff - 1J Diesel Engine Lube Oil System
Calculations
Combustible Loading Analysis North Anna Power Station
Corrective Action
Documents
CR
1166332
Corrective Action
Documents
CR
1166425
Drawings
2050-FM-309B-4 Fire Barrier Penetrations Emergency Diesel Generator
Room Sh. 2
Engineering
Evaluations
ETE-NA-2011-
21
Evaluation of Permanently Stored Combustible Material
Fire Plans
1-FS-AB-1
Auxiliary Building Fire Fighting Strategy
Fire Plans
1-FS-SW-1
Service Water Pumphouse Units 1 and 2
Procedures
0-FS-CR-1
Control Room - Units 1&2 Safe Shutdown Equipment
Procedures
1-FS-DR-1
Unit 1 and 2 Emergency Diesel Engine Rooms
Procedures
CM-AA-FPA-100
Fire Protection/Appendix R (Fire Safe Shutdown) Program
Procedures
CM-AA-FPA-101
Control of Combustible and Flammable Materials
Procedures
CM-AA-FPS-101
Transient Combustible Loading Limits and Restrictions
Procedures
Fire Protection Maintenance
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CRs 1149869,
1145284
Engineering
Evaluations
1-CH-1B (a)(1)
action plan
UA hours exceeded performance criteria
08/24/2020
Procedures
ER-AA-MRL-100
Implementing Maintenance Rule
Corrective Action
Documents
CR
1167419
Drawings
11715-FM-096A,
Sheet 1
Flow/Valve Operating Numbers Diagram Safety Injection
System
Drawings
11715-FM-096A,
Sheet 2
Flow/Valve Operating Numbers Diagram Safety Injection
System
Procedures
0-MCM-1403-02
High Pressure (HP) Turbine Enclosure Removal and
Installation
Procedures
1-PT-138.1
HHSI Flow Balance
Procedures
OP-NA-601
Protected Equipment
Procedures
15
High Risk Plan Actions
Work Orders
Unit 1 High Pressure Turbine HP Enclosure Removal
Corrective Action
Documents
CR
1161726
Corrective Action
Documents
CR
1165547
Corrective Action
Documents
CR
1163149
Procedures
2-PT-74.2B
Component Cooling Pump 2-CC-P-1B Test
Procedures
2-PT-82.9H
2H Emergency Diesel Generator Test (Local Operation)
Procedures
- Attachment 1
Operations Site Specific Instructions for Replacement of
Indicating Light Bulbs
Work Orders
Work Orders
2/10/2020
Drawings
1700236-12050-
Engineering
Changes
DC NA-17-00236
Station Battery Chargers 2-III, 2-IV, and 2C-II Replacement
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
Corrective Action
Documents
CR
1165457
Corrective Action
Documents
CR
1165455
Miscellaneous
BCT-2000
Software and
BCT-128 and
BCT-256
Users Guide
Miscellaneous
IEEE Standard Criteria for Class 1E Power Systems for
Nuclear Power Generating Stations
9/16/1971
Miscellaneous
IEEE Recommended Practice for Maintenance, Testing, and
Replacement of Large Lead Storage Batteries for
Generating Stations and Substations
3/9/1987
Miscellaneous
IEEE Recommended Practice for Sizing Large Lead Storage
Batteries for Generating Stations and Substations
9/30/1983
Miscellaneous
NA-VTM-000-59-
N163-00001
Vendor Technical Manual: Type SU/SD High Speed
Increasers & Reducers
Procedures
0-ECM-2820-01
Electrical Corrective Maintenance - Lamp Socket
Replacement
Procedures
0-EMP-0302-12
BBC/ITE 4160-Volt Type 5HK Breaker Change Out
Procedures
1-PT-14.1
Operations Periodic Test - Charging Pump 1-CH-P-1A
Procedures
1-PT-81.1B
Emergency Diesel Generator Fuel Oil Transfer Pumps 1-
EG-P-1JA and 1-EG-P-1JB Quarterly Test
Procedures
1-PT-82.4B
1J Diesel Generator Test (Start by ESF Actuation)
Procedures
2-EPM-0108-03
Testing of Station Battery Charger 2-III Alarms
Procedures
2-OP-6.8 OTO1
Slow Start and Operation of 2H Emergency Diesel
Generator
OTO1
Procedures
2-PT-82H.1
Lubrication and Rotation of 2H Emergency Diesel Generator
Procedures
2-PT-87.3J
Station Battery Charger 2-III Service Test
2-OTO-2
Procedures
2-PT-87.3J
Station Battery Charger 2-III Service Test
10/22/2001
Work Orders
Work Orders
Work Orders
01/20/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
21 Outage Plan Safety Review-North Anna Unit 1
03/08/2021
Miscellaneous
1R28 Shutdown Risk Assessment
03/14/2021 -
03/30/2021
Procedures
Procedures
1-GOP-13
Alternate Core Cooling Method Assessment
Procedures
1-GOP-13.0
Alternate Core Cooling Method Assessment Guidelines
Procedures
1-OP-3.3
Unit Shutdown From Mode 4 to Mode 5
Procedures
1-OP-3.7
Unit Shutdown from Mode 1 to Mode 5 for Refueling
Procedures
1-OP-4.1
Controlling Procedure for Refueling
Procedures
1-OP-4.1A
Mode Change Checklist from Mode 6 to 5
Procedures
1-OP-5.4
Draining the Reactor Coolant System
Procedures
Shutdown Risk Management
Corrective Action
Documents
CR
1132296
Corrective Action
Documents
CR
27749
Corrective Action
Documents
CR
1155243
Corrective Action
Documents
CR
1150010
Corrective Action
Documents
CR
1153596
Corrective Action
Documents
CR
1163588
Miscellaneous
North Anna Power Station Unit 1 Inservice Testing Program
Plan for Pumps and Valves - Fifth Inservice Testing Interval
Miscellaneous
North Anna Power Station Unit 2 Inservice Testing Program
Plan for Pumps and Valves - Fifth Inservice Testing Interval
Miscellaneous
NU-REG 1482
Guidelines for Inservice Testing at Nuclear Power Plants
Procedures
1-PT-36.5B
Solid State Protection System Output Slave Relay Test
(Train B)
Procedures
1-PT-57.1B
Emergency Core Cooling Subsystem - Low Head Safety
Injection Pump (1-SI-P-1B)
Procedures
1-PT-71.2Q
1-FW-P-3A, A Motor Driven AFW Pump and Valve Test
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
1-PT-82H
1H Emergency Diesel Generator Slow Start Test
Procedures
2-PT-71.1Q
2-FW-P-2, Turbine Driven Auxiliary Feedwater Pump and
Valve Test
Procedures
2-PT-71.2Q
2-FW-P-3A, A Motor-Driven AFW Pump, and Valve Test
Procedures
Procedure Use and Adherence
Procedures
ER-AA-IST-10
ASME Inservice Testing Program
Procedures
Conduct of Operations
Procedures
Human Performance
Work Orders
Work Orders
Work Orders
Corrective Action
Documents
CR
1166343
Corrective Action
Documents
CR1155565, CR1155825, CR1157022, CR1157454,
CR1157847, and CR1158379
Various
Miscellaneous
List of current or potential Locked High Radiation Areas
(LHRAs) and Very High Radiation Areas (VHRAs)
2/11/2021
Miscellaneous
List of
Radioactive
Material (RAM)
storage areas and
satellite
Radiologically
Controlled Areas
(RCAs) [RMAs
and RCAs Inside
and Outside the
Protected Area]
2/26/2021
Miscellaneous
Unit 1 & 2 Spent
Fuel Pool non-fuel
inventory lists
2/18/2021
Procedures
Access Controls for High and Very High Radiation Areas
Procedures
Radiological Posting
Procedures
Unrestricted Release of Material
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Personnel Contamination Monitoring and Decontamination
Procedures
Radiological Control Areas
Procedures
Discrete Radioactive Particle Control
Procedures
Radiation Work Permits
Procedures
Radiological Risk Assessment Process
Procedures
Providing HP Coverage During Work
Radiation
Surveys
Unit 1
Containment
Initial Entry
Survey
All elevations except reactor cavity and incore sump.
03/14/2021
Radiation
Surveys
Unit 1 Reactor
Cavity initial entry,
except transfer
canal
03/14/2021
Radiation
Surveys
Unit 1 Seal Table
during Eddy
Current
03/16/2021
Radiation
Surveys
Unit 1 Transfer
Canal initial entry
03/15/2021
Radiation Work
Permits (RWPs)
21 Non-Outage
RWP List
Including dose and dose rate alarm setpoints
01/22/2021
Miscellaneous
Radioactive Waste/Material Qualification List
9/25/2020
Miscellaneous
List of Category 1 and 2 radioactive material storage areas
2/1/2021
Miscellaneous
0-PT-153
Annual National Source Tracking Reconciliation (for 2019,
20, and 2021)
January 2019,
20, and
21
Miscellaneous
CFR Part 37
Radiation Protection Qualification Roster
2/16/2021
Miscellaneous
C-HP-1071.010,
20 Annual Radioactive Source Inventory
01/08/2020
Miscellaneous
C-HP-1071.010,
21 Annual Radioactive Source Inventory
01/202021
Miscellaneous
HPTCTP-20-
Cycle-03
Radiation Protection Annual Training Attendance Rosters
(June/July 2020)
Various
Miscellaneous
HPTCTP-20-
20 Radioactive Waste Packaging, Transportation, and
Various
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Cycle-03-LP-1
Disposal Training (attendance roster(s) and instructor
presentation with notes)
Procedures
C-HP-1071.040
PACKAGING AND SHIPMENT OF RADIOACTIVE
MATERIAL
Procedures
C-HP-1072.010
PACKAGING RADIOACTIVE WASTE
Procedures
C-HP-1072.050
RADIOACTIVE WASTE TRANSFER TO LICENSED
WASTE PROCESSORS
Procedures
C-HP-1072.070
RADIOACTIVE WASTE DISPOSAL USING THE
ENERGYSOLUTIONSCONTAINERIZED WASTE FACILITY
Procedures
C-HP-1072.071
RADIOACTIVE WASTE DISPOSAL USING THE
ENERGYSOLUTIONSBULK WASTE FACILITY
Procedures
HP-1032.134
GUIDANCE/SPECIAL INSTRUCTIONS FOR PLANT
SYSTEMS FILTER CHANGEOUT
Procedures
HP-1032.135
GUIDANCE/SPECIAL INSTRUCTIONS FOR FILTER
CHANGE OUT WITHOUT USING SHIELDED CASK
Procedures
HP-1071.022
PLACING SECURE ENVIRONMENTAL CONTAINERS
(SEC) INTO STORAGE INSIDE THE PROTECTED AREA
Procedures
HP-1072.020
SAMPLING, ANALYZING, AND CLASSIFYING SOLID
RADIOACTIVE WASTE
Procedures
HP-1072.080
RADIOACTIVE WASTE TRANSFER TO ERWIN
RESINSOLUTIONS, AND ENERGY SOLUTIONS WASTE
PROCESSOR FOR (TYPE B CASK), TN
Procedures
HP-1072.090
RADIOACTIVE WASTE DISPOSAL TEXAS COMPACT
WASTE DISPOSAL FACILITY (CWF)
Procedures
HP-1072.100
GUIDANCE FOR PRIMARY RESIN TRANSFER TO A
LINER
Procedures
HP-1072.300
PLACING, TRANSFERRING AND RETRIEVING FILTERS
WITHIN OSSC STORAGE
Procedures
RMSIP-1
Physical Protection of Category 1 and 2 Radioactive
Material
Procedures
Radioactive Material Control Program
Procedures
Radioactive Material Control
Procedures
Control of Safeguards Information, Security-Related
Information, and Controlled Unclassified Information
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
SY-AA-TR-300
Nuclear Security Training 10 CFR 37 Requirements
Procedures
VPAP-2104
Radioactive Waste Process Control Program (PCP)
Radiation
Surveys
1-RC-SV-1551B
Unit 1 Pressurizer Safety Valve after removal from system.
03/16/2021
Radiation
Surveys
L-82683-1
Part 61 Anion Resin Survey
Radiation
Surveys
L-83760-2
Part 61 Common DAW Survey
Radiation
Surveys
L-84754-1, L-
90653-1
Part 61 Spent Resin Holdup Tank Surveys
Radiation
Surveys
RM Receipt # 21-
RMR-13
CoreVis Box 2 Rad Material Incoming Rad Shipment Survey
03/17/2021
Radiation
Surveys
RM-B1-301
Shipment survey of package containing pressurizer safety
valve 1-RC-SV-1551B.
03/16/2021
Self-
Assessments
Audit 20-06
Radiation Protection, Process Control Program, and
Chemistry
9/16/2020
71151
Corrective Action
Documents
CR1154543, and CR1165012
Various
Corrective Action
Documents
CR
1156615
Corrective Action
Documents
CR
1164001
Corrective Action
Documents
CR
1165201
Corrective Action
Documents
Resulting from
Inspection
CR
1169722
Procedures
0-MCM-1112-02
Installation of the Reactor Vessel Lower Internals