IR 05000338/2021003
| ML21316A247 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/12/2021 |
| From: | Stewart Bailey Division Reactor Projects II |
| To: | Stoddard D Virginia Electric & Power Co (VEPCO) |
| References | |
| IR 2021003 | |
| Download: ML21316A247 (26) | |
Text
November 12, 2021
SUBJECT:
NORTH ANNA POWER STATION - INTEGRATED INSPECTION REPORT 05000338/2021003 AND 05000339/2021003
Dear Mr. Stoddard:
On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at North Anna Power Station. On October 14, 2021, the NRC inspectors discussed the results of this inspection with Fred Mladen and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation 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: NPF-4 and NPF-7 Report Numbers: 05000338/2021003 and 05000339/2021003 Enterprise Identifier: I-2021-003-0020 Licensee: Virginia Electric & Power Co.
Facility: North Anna Power Station Location: Mineral, VA Inspection Dates: July 01, 2021 to October 31, 2021 Inspectors: K. Carrington, Resident Inspector J. Diaz-Velez, Senior Health Physicist J. McHugh, Sr. Reactor Technology Instructor W. Pursley, Health Physicist J. Rivera, Health Physicist J. Seat, Senior Project Engineer G. Smith, Senior Resident Inspector D. Strickland, Reactor Inspector M. Tobin, Senior Resident Inspector J. Zeiler, Senior Resident Inspector Approved By: Stewart N. Bailey, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
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
Unit 2 A Charging Pump Breaker Not In Fully Connected Position Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.1] - 71111.19 Systems NCV 05000339/2021003-01 Resources Open/Closed A finding of very low safety significance (Green) and associated non-cited violation of Technical Specification 5.4.1.a, was self-revealed on August 31, 2021, when the safety-related 4160 Volt (V) breaker for the Unit 2 'A' charging pump was discovered not fully racked into the "CONNECT" position, after the licensee failed to properly preplan and perform post-maintenance testing following predictive maintenance affecting the performance of safety-related equipment.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000338,05000339/20 URI 2021-012 for North 71111.21N.05 Closed 21012-01 Anna Power Station Unit 1 and Unit 2. Following a fire-induced hot short stall event of North Anna Power Station chemical and volume control system motor-operated valves, it is uncertain whether the valves' pressure boundary components would be compromised and challenge safe shutdown capability.
PLANT STATUS
Unit 1 began the inspection period operating at or near rated thermal power. On September 12, 2021, the unit was shutdown for a planned mid-cycle maintenance outage to repair the no. 9 turbine bearing and Unit 1 reactor vessel inner o-ring leakage. The unit was restarted and the turbine generator was synchronized to the grid, on September 20. The unit was returned to operating at or near rated thermal power on September 21, 2021, where it remained through the end 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 (COVID-19), resident and regional 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, increasing the amount of time on site as local COVID-19 conditions permitted.
As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; 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 a portion 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
External Flooding Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on August 6, 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 1 spent fuel pit cooling system prior to the Unit 1 mid-cycle outage, on September 9, 2021.
- (2) Unit 1 'A' and 'B' motor-driven auxiliary feedwater (MDAFW) pump systems following planned maintenance, on September 19, 2021.
- (3) Unit 1 main control room (MCR) ventilation system (air handlers and chilled water system) following a failure of the Unit 1 'C' MCR chiller (1-HV-E-4C), on September 29, 2021.
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 casing cooling system, on September 10, 2021.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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) Unit 2 main steam valve house, on July 20, 2021.
- (2) Unit 1 normal switchgear, on July 21, 2021.
- (3) Unit 2 normal switchgear, on July 21, 2021.
- (4) Unit 2 safeguards alley, on July 21, 2021.
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Unit 1 and 2 emergency switchgear room, on September 10, 2021.
71111.07A - Heat Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) Unit 2 component cooling heat exchanger 1A, 2-CC-E-1A, on July 29, 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 main control room during Unit 1 shutdown for a forced outage, on September 12, 2021.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated Drill SXG-55; Licensed Operator Requalification Program, on August 17, 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) Bearing cooling water system functions BC002 and BC004, on August 4, 2021.
- (2) Plant computer system functions CM002 and CM004, on July 28, 2021.
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSCs remain capable of performing their intended function:
===59203308933, and Unit 2 emergency diesel generator (EDG) air start solenoid operated valve per WO 59203276141.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) ===
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) Hot weather alerts in June and July, on July 19, 2021.
- (2) Elevated risk during the 2H EDG extended nine day outage, on July 21, 2021.
- (3) Safe shutdown Appendix R cables requiring an hourly fire watch, on August 4, 2021.
- (4) Potentially missed risk evaluation for excavation for wood retrieval from Unit 1 containment dome, on August 17, 2021.
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) VG-RM-180-1/2 declared nonfunctional due to ground and sporadic fluctuations during VG-RM-179 maintenance, on July 16, 2021.
- (2) Unit 2 containment sump check valve stuck open, on July 27, 2021.
- (3) Unit 2 turbine driven auxiliary feedwater pump low oil level, on August 6, 2021.
- (4) Unit 2 charging pump gear box oil level high, on August 16, 2021.
- (5) Unit 1 containment barrier partially degraded due to foreign material found in concrete during American Society of Mechanical Engineers (ASME)Section XI inspections, on September 21, 2021.
- (6) Unit 1 reactor vessel leak-off line through wall leak, on September 17, 2021.
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Design Change NA-21-00056, Temporary Missile Shield for Unit 1 Containment, on September 22, 2021.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Unit 2 'A' charging pump breaker post-maintenance testing (PMT) following predictive maintenance and discovery of breaker not in required position, on September 28, 2021.
- (2) Unit 1 turbine driven auxiliary feedwater (TDAFW) system PMT following turbine inboard bearing oil line maintenance, on September 19, 2021.
- (3) Unit 1 reactor vessel leak-off piping PMT following weld repairs, on September 19, 2021.
- (4) Unit 2 'H' emergency diesel generator PMT following an extended maintenance outage, on August 11, 2021.
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated Unit 1 mid-cycle forced outage activities from September 12 to 21, 2021.
===71111.21N.05 - Fire Protection Team Inspection (FPTI) Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)
During an NRC Triennial Fire Protection Inspection (TFPI), as documented in NRC Inspection Report 05000338 AND 05000339/2021012, inspectors documented an unresolved item (URI) regarding the licensees evaluation of certain motor operated valves (MOVs) in North Anna Power Stations (NAPS) Unit 1 and Unit 2 Chemical and Volume Control System (CVCS). For these MOVs, the NRC was verifying that fire damage to control cabling would not cause an electrical hot short, bypassing thermal overload protection, and result in the loss of pressure boundary integrity and potentially reactor coolant inventory. In response, North Anna provided an evaluation, 1114-0093-CALC-001, Evaluation of North Anna Power Station (NAPS) MOV Pressure Boundaries for a Hot-Short Stall Event.
The NRC Team reviewed this calculation to ensure the licensee's evaluation adequately addressed the potential for compromise of analyzed MOV pressure boundaries. Additionally, the Inspectors posed additional questions regarding the effect on the sealing performance of the packing/joint seals of the valves. Following the review of the provided calculation as well as the responses to the NRCs inquiry, the NRC Team determined that the postulated motor stall events would not be expected to cause excessive leakage from the CVCS valves sealing components and that the valves would retain their pressure boundary integrity.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Unit 1 containment dome surveillance inspection per ER-AA-NDE-VT-606, on August 25, 2021.
Inservice Testing (IP Section 03.01) ===
- (1) Unit 1 'B' low head safety injection pump comprehensive inservice pump test, on
===August 2, 2021.
FLEX Testing (IP Section 03.02) (1 Sample)===
- (1) Shared FLEX diesel generator yearly inspection per 00-BDB-GEN-1C-UNIT, on August 4, 2021.
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) The 'A' Team emergency preparedness drill on July 13,
RADIATION SAFETY
71124.02 - Occupational ALARA Planning and Controls
Radiological Work Planning (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensees radiological work planning by reviewing the following:
- (1) RWP 21-1224, NUHOMs EOS Cask Loading Campaign Preparation Activities.
- (2) 2021 UNIT 1 REFUELING OUTAGE (1 EOC 28) Shutdown Chemistry Plan.
- (3) 2020 Unit 2 ALARA Refueling Outage Report for N2R27.
Verification of Dose Estimates and Exposure Tracking Systems (IP Section 03.02) (5 Samples)
The inspectors evaluated dose estimates and exposure tracking.
The inspectors reviewed the following as low as reasonably achievable (ALARA) planning documents and outcome evaluations:
- (1) RWP 21-1224, NUHOMs EOS Cask Loading Campaign for Three Casks.
- (2) RWP 21-3251 Disassemble and Reassemble Reactor Vessel Head to include all maintenance activities.
- (4) 2020 Unit 2 ALARA Refueling Outage Report for N2R27.
- (5) North Anna Unit 1 - Cycle 27 Primary Coolant Shutdown Chemistry Evaluation RWP 21-3753 Work in the Transfer Canal; to include removing and replacing transfer canal blank flange and transfer cart inspection.
Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (3 Samples)
The inspectors reviewed as low as reasonably achievable practices and radiological work controls.
- (1) RWP 21-1216, U1 Reactor Building Entry at Power to Replace Solenoid.
- (2) RWP 21-1216, U2 Reactor Building Entry at Power Using Drone to Evaluate Reactor Head "O" Ring Leakage.
- (3) RWP 21-1224, NUHOMs EOS Cask Loading Campaign Preparation Activities.
Radiation Worker Performance (IP Section 03.04) (1 Sample)
The inspectors evaluated radiation worker and radiation protection technician performance during:
- (1) RWP 21-1216, U1 Reactor Building Entry at Power to Replace Solenoid.
RWP 21-1216, U2 Reactor Building Entry at Power Using Drone to Evaluate Reactor Head "O" Ring Leakage.
RWP 21-1224, NUHOMs EOS Cask Loading Campaign Preparation Activities.
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walkdowns and Observations (IP Section 03.01) (4 Samples)
The inspectors evaluated the following radioactive effluent systems during walkdowns:
- (1) Plant vent stacks A and B radiation monitoring system.
- (2) Steam generator high-capacity blowdown radiation monitoring system.
- (3) Liquid radwaste effluent monitoring system.
- (4) Ventilation filtration systems for plant vent stacks "A" and "B."
Sampling and Analysis (IP Section 03.02) (3 Samples)
- (1) Evaluated compensatory sampling for Unit 2 steam generator high capacity blowdown radiation monitor that went out of service on February 24, 2021.
- (2) Evaluated compensatory sampling for ventilation vent B radiation monitor that went out of service on July 13, 2021.
- (3) Observed compensatory sampling for out-of-service process vent system radiation monitor.
Dose Calculations (IP Section 03.03) (2 Samples)
The inspectors evaluated the following dose calculations:
- (1) Liquid clarifier continuous release sampled on May 1, 2021.
- (2) Plant vent stacks "A" and "B" sampled on May 07, 2021.
71124.07 - Radiological Environmental Monitoring Program
Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.
Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.
GPI Implementation (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative program to identify incomplete or discontinued program elements.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===
- (1) Unit 1 (July 1, 2020 through June 30, 2021).
- (2) Unit 2 (July 1, 2020 through June 30, 2021).
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
- (1) Unit 1 (July 1, 2020 through June 30, 2021).
- (2) Unit 2 (July 1, 2020 through June 30, 2021).
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)
- (1) Unit 1 (July 1, 2020 through June 30, 2021).
- (2) Unit 2 (July 1, 2020 through June 30, 2021).
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) Unit 1 (August 01, 2019 through July 31, 2021)
Unit 2 (August 01, 2019 through July 31, 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 (work coordination) that might be indicative of a more significant safety issue.
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Follow Up (IP Section 03.01)
- (1) The inspectors evaluated an unanalyzed condition associated with an Appendix R noncompliance affecting the emergency diesel generators on both units and the licensees initial response on July 22,
INSPECTION RESULTS
Unit 2 A Charging Pump Breaker Not In Fully Connected Position Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.1] - 71111.19 Systems NCV 05000339/2021003-01 Resources Open/Closed A finding of very low safety significance (Green) and associated non-cited violation of Technical Specification 5.4.1.a, was self-revealed on August 31, 2021, when the safety-related 4160 Volt (V) breaker for the Unit 2 'A' charging pump was discovered not fully racked into the "CONNECT" position, after the licensee failed to properly preplan and perform post-maintenance testing following predictive maintenance affecting the performance of safety-related equipment.
Description:
North Anna Unit 2 contains three charging pumps which inject coolant into the reactor coolant system. One pump is powered by each emergency electric bus and the third pump can be powered by either emergency electric bus. The charging pumps also provide high-head safety-injection which will provide borated water during the injection phase of the design basis accident.
On August 5, 2021, the licensee tagged the A charging pump out of service for predictive maintenance in accordance with Tagout TR 2-21-0007. This required placing a danger tag on 4160V pump breaker 25H6, placing the A charging pump's control switch in "Pull-to-Lock," and racking the 25H6 breaker into the "DISCONNECT" position in accordance with licensee Maintenance Operating Procedure (MOP), 2-MOP-8.01, 2-CH-P-1A, A Charging Pump Breaker, and 0-GOP-26.9, 4160-Volt Breaker Operation." On August 6, 2021, following completion of the predictive maintenance, the licensee removed the tags from breaker 25H6, but did not fully rack the breaker into the "CONNECT" position as required, and placed the A charging pumps control switch in "Automatic."
On August 31, 2021, the licensee tagged the 'B' charging pump out of service for scheduled testing per 2-PT-36.29, "Operability Testing of Interlocks from Control Circuits for Breaker 25J6, Charging Pump 2-CH-1B." To establish the initial conditions for testing, an electrical jumper is installed in the breaker cubicle for the 'A' charging pump breaker (25H6). During implementation of the step, the licensee found that the 'A' charging pump breaker was not completely racked into the CONNECT position. The breaker was found with its "Trip" push button slightly depressed and breaker pivot (racking) arm rotated out of the expected position. This condition would result in the breaker re-opening after an attempted closure. The Unit 2 A charging pump control switch was subsequently placed in "Pull-to-Lock" in the main control room and a preliminary investigation was launched to determine the cause of the improper configuration. The licensee's preliminary investigation determined that the identified condition would have prevented the 'A' charging pump 4160V breaker (25H6)from closing in an emergency.
The residents performed a review of the issue, referencing the licensee's tagout instructions, implementing procedures 2-MOP-8.01 and 0-OP-26.9, 0-GOP-26.9, and operator rounds. During their review, the inspectors noted the operator rounds' acceptance criteria contained vague instructions for distinguishing between a breaker in normal alignment versus off-normal alignment, only requiring verification of target and charging springs status, which do not entirely inform operators if a breaker is fully racked in position or in an off-normal alignment. The inspectors noted a job aid was present on the breaker, which displayed the proper positioning of the breaker racking arm, but had not been followed or referenced. Additionally, the inspectors noted that Step 1 of the MOP referenced in tagout TR 2-21-0007 required the licensee to utilize 0-GOP-26.9, "4160 Breaker Operation," to perform breaker manipulations and concurrently verify the breaker trip pushbutton was not in the depressed position. The inspectors noted that 0-OP-26.9, "4160 Breaker Operation,"
(which was also referenced in the procedure) also had a note warning that with the breaker trip pushbutton depressed, the breaker may attempt to close in during an emergency but will not remain closed.
Corrective Actions: Upon discovery of the condition, the licensee properly racked the breaker into the "CONNECT" position, performed an extent of condition walkdown of all 4160V breakers throughout the plant, and captured the issue in its corrective action program. A licensee human performance review board investigation was also conducted, which identified an operator training gap related to racking 4160V breakers.
Corrective Action References: Condition Report CR1179746
Performance Assessment:
Performance Deficiency: The licensees failure to preplan and perform post-maintenance testing following predictive maintenance, to ensure operability of the Unit 2 'A' charging pump, 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 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, the 4160V breaker 25H6 was nonfunctional following maintenance activities because it was not properly racked into the cubicle.
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 Green based on a detailed risk evaluation performed by a senior reactor analyst (SRA). The SRA modelled the condition using the North Anna Units 1 & 2 SPAR model, Version 8.56, dated February 28, 2017, and SAPHIRE 8, Version 8.2.3. The exposure period was from the maintenance on August 5, 2021, until discovery and return to service on August 31, 2021, a period of 25 days. Charging Pump 'A' was set to Failure to Start. The dominant accident sequence was a small break loss of coolant accident, with a failure to perform a secondary side cooldown, and failure of high-pressure recirculation. The change in Core Damage Frequency for a 25-day exposure period was approximately 1 E-8, which corresponds to a finding of very low safety significance (Green).
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. The finding had a cross-cutting aspect in the Human Performance area of Resources because the licensee failed to ensure adequate resources were available to support nuclear safety. Specifically, the licensee failed to ensure training, operator rounds, and procedural instructions were sufficient to identify the Unit 2 'A' charging pump breaker was not properly racked in position following maintenance.
Enforcement:
Violation: Technical Specifications 5.4, "Procedures," requires, in part, written procedures be established, implemented, and maintained covering activities in Regulatory Guide 1.33, "Quality Assurance Program Requirements," Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Section 9, "Procedures for Performing Maintenance," requires that "maintenance that can affect the performance of safety-related equipment be properly preplanned and performed."
Contrary to the above, the licensee failed to preplan and perform post-maintenance testing following predictive maintenance that could affect the Unit 2 safety-related 'A' charging pump. As a result, from August 5 to August 31, the Unit 2 'A' charging pump remained inoperable due to its 4160V breaker being not properly racked in the "CONNECT" position. This would have prevented the pump from starting in an emergency.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Semi-Annual Trend Results 71152 The resident inspectors reviewed the licensees corrective action program documents to determine if there exists a negative trend in the area of work management and configuration control. Such a trend, if not corrected, has the potential to result in a significant misposition event that renders a safety system inoperable. The following examples demonstrate a negative trend in work management and configuration control events during the last 12 months:
- CR1175625 - NRC identified minor violation for a thermostat setpoint being outside of procedurally driven setpoints
- CR1179746 - A 4160 volt breaker found not fully in the CONNECT position
- CR 1172105 - Unit 1 cation bed bypass valve found out of its expected position
- CR1179864 - NRC identified CR for the service water pump house tornado missile door open when it should have been partially shut per procedure due to thunderstorms in the area
- CR1169954 - Self-revealed NRC minor violation for the outside recirculation spray valve found out of its expected position
- CR1169347 - Breaker 1-EE-BKR-1H1-4-C3R found out of its expected position
- CR1181870 - Main Control room chiller thermostats have incorrect replacement frequency
- CR1180098 - Containment penetration pressure transmitter surveillance was missed and exceeded the drop-dead date
- CR1179360 - Unit 1 anticipated transient without scram mitigation system actuation circuitry (AMSAC) preventative maintenance (PM) schedule not updated to reflect the new requirements when the system was replaced
- CR1179232 - Unit 1 feedwater level transmitter 1486 PM schedule not updated to reflect the new requirements when the transmitter was replaced
- CR1171597Unit 2 circulating water pump running without the normally installed screen protecting from rotating equipment.
The inspectors note that each of the above work management or configuration control issues did not adversely affect nuclear safety; however, a continued degrading trend could lead to more significant issues. This trend closely aligns with a previously identified trend on human performance errors. The station continues efforts to improve performance in this area using their human error review board process, as well as all-hands meetings, and one-on-one discussions with individuals on an as-needed basis, and the resident office continues to monitor this trend closely.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 14, 2021, the inspectors presented the integrated inspection results to Fred Mladen and other members of the licensee staff.
- On August 5, 2021, the inspectors presented the RP Public Radiation Safety Inspection, results to Ms. Lisa Hilbert, Plant Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.01 Miscellaneous NAPS UFSAR Revised Analysis, Probable Maximum Flood 55
Appendix 2A
Procedures 0-GOP-4 Cold Weather Operations 67
0-PT-9.4 Inspection of Roof Drains, Yard Drains, Roofs, and BDB Lip 5
Flood Barriers
71111.04 Corrective Action CR1180327 NRC Identified Debris on Top of the SFP Cooling Pumps 09/10/2021
Documents Suction Strainer
Resulting from CR1180880 Unit 1 3A MDAFW pump inboard packing gland nut found 09/19/2021
Inspection loose
CR1180896 NRC Identified: Debris Under U1 TDAFW Pump House 09/20/2021
Grating
Drawings 11715-FB-040D, Flow/Valve Operating Numbers Diagram Air Conditioning 47
Sheet 1 Condenser Water System Sh. 1 of 3
11715-FB-40A, Flow Diagram Air Conditioning Chilled Water Systems - Sh. 21
Sheet 1 1 of 3
11715-FM-74A, Flow/Valve Operating Numbers Diagram Feedwater System, 57
Sheet 1 Unit 1
11715-FM-74A, Flow/Valve Operating Numbers Diagram Feedwater System, 48
Sheet 3 Unit 1
Miscellaneous MODULE Secondary Plant Ventilation Systems 12/03/2020
NCRODP-36-NA
Procedures 1-OP-21.6 Main Control Room and Relay Room Air Conditioning 39
1-OP-31.2A Valve Checkoff - Auxiliary Feedwater 25
1-PT-71.12 AFW System Valve Position Verification 7
2-OP-7.10A Valve Checkoff - Casing Cooling System 12
71111.05 Corrective Action CR1176961
Documents CR1177759
Resulting from
Inspection
Fire Plans 0-FS-S-4 Unit 1 & 2 Normal Switchgear Rooms 5
2-FS-MS-1 Main Steam Valve House 5
2-FS-SG-1 Safeguards Area Safe Shutdown Equipment Unit 2 5
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.06 Calculations CALC-NFL-SM- North Anna Internal Flooding Integration Into the At-Power 0
1342 (ADD-000- PRA Models
001)
NA-CALC-NFL- Internal Flood Analysis for the IPE 04/16/1993
234MAF.N
NA-CALC-NFL- North Anna Internal Flooding Integration Into The At-Power 0
SM-1342 PRA Models
NA-CALC-NFL- North Anna Internal Flooding Integration Into The At-Power 0
SM-1342 (ADD- PRA Models
000-00B)
NA-CALC-NFL- PRA Evaluation of North Anna Chiller Room Dike Bypass 1
SM-1503 Event N-2005-2565
Corrective Action CA7362095 Engineering to review the licensing and design basis of the 08/20/2018
Documents sump pumps
Corrective Action CR1177759
Documents CR1177763
Resulting from
Inspection
Drawings 11715-FB-201A Flow/Valve Operating Numbers Diagram Secondary Plant 4
Drain System
11715-FB-201A Flow/Valve Operating Numbers Diagram Secondary Plant 4
Drain System
11715-FB-26A Plumbing Service Building 21
11715-FB-26B Plumbing Service Building 21
NA-DWG-000- FLOW/VALVE OPERATING NUMBERS DIAGRAM 4
11715-FB-201A SECONDARY PLANT DRAIN SYSTEM NORTH ANNA
SH-002 POWER STATION UNITS 1 & 2
NA-DWG-000- ARRANGEMENT SERVICE BUILDING SHEET 3 NORTH 19
11715-FM-5C ANNA POWER STATION
NA-DWG-000- LIGHTING PANELBOARD SCHEDULE 9
11715-LP-1512 LTG PANEL 1-EP-PNL-1S12 (LTG PNL-05)
NA-DWG-000- LIGHTING PANELBOARD SCHEDULE 9
2050-LP-2512 LTG PANEL 2S12 (LTG PNL-05-2)
Engineering NA-09-00136 Removal of Unit 1 Air Handling Room Floor Drains 06/15/2009
Inspection Type Designation Description or Title Revision or
Procedure Date
Changes NA-20-00050 Installation Instructions for Lift-Hinge Flood Gates 2
NA-DCP-000-59- Emergency Switchgear Sump Modifications / NAPS / Units 1 05/10/2006
DCP-05-147 &2
Engineering NA-ETE-000- Beyond Design Basis - FLEX Strategy Basis Document and 14
Evaluations ETE-CPR-2012- Final Integration Plan
0012 (50.59AP)
Miscellaneous ACE 000337 ACE to Eng. ACE is to address conditions noted on CR 03/16/2007
008734 and CR 008737
Self-Assessments NA-NOTEBK- NAPS PROBABILISTIC RISK ASSESSMENT MODEL 1
PRA-NAPS-IF.2 NOTEBOOK
71111.07A Miscellaneous 2-CC-E-1A As
Found 05-25-
21
Engineering Logs 05/25/2021
Procedures ER-AA-HTX-1002
Work Orders WO 59203270062 Cleaning and Plugging of Component Cooling Heat 06/01/2021
Exchanger Tubes
71111.12 Miscellaneous RCS Leak Rate Program for Execution on Plant Computer 2
System- Design Specification
Tracking Group and Performance Criteria Basis Documents
for Maintenance Rule Functions BC002, BC003
A(1) Action Plan Report- Perform MRule Functional Failure
Evaluation for 2-BC-P-1A Pump Casing is Not Full
Maintenance Rule Evaluations
NA-VTM-59- Sequence of Events Recorder 1
D840-00001
Work Orders WO 59203276141
WO 59203308933
71111.13 Corrective Action CR1177651
Documents
Resulting from
Inspection
Miscellaneous Operations Narrative Logs for June and July 2021
North Anna Plan of the Week July 2021
Inspection Type Designation Description or Title Revision or
Procedure Date
Work Week 4- North Anna Plan of Week (POW) - July 11 to
July 31, 2021
71111.15 Calculations CEM-0208 Evaluation of Missile Barrier for North Anna Power Station 10/29/2019
Service Water Pump House Installed per DC NA-18-00125
Corrective Action CA242962 Document Previous Operability (due 20 days) 09/17/2012
Documents CR1177199 App R Concern Identified with Cable Separation Associated 07/20/2021
with U1&U2 EDG and Emergency Bus Operation
CR1177264 Missile Protection on Unit 1 Containment is Less than 07/21/2021
Required
CR1177270 Active Packing and fitting Leakage on 1-RC-33
CR1177293
Drawings 11715-CBM- ISI Classification Boundary Dwg Interval 5, Reactor Coolant 0
093A-5 System- Loop 1
Engineering NA-21-00056 Temporary Missile Shield for Unit 1 Containment 07/21/2021
Changes
Engineering CEP 00-0031 Evaluation of Concrete Block and Structural Steel Fire 3/1/2000
Evaluations Barriers
ET CCE 01-0007 Initial Concrete Containment Assessment, North Anna 08/13/2001
Power Station, Unit 1
Miscellaneous Test Oil Industrial Analysis - 1-CH-P-1A 08/13/2021
NAPS Appendix 48
R Report
ODM CA8453522 Unit 1 Reactor Vessel Flange Leakoff Hi Temp Annunciator 6/28/2021
SDBD-NAPS-RC System Design Basis Document for Reactor Coolant System 29
Procedures ER-AA-NDE-VT- Nondestructive Examination Procedure 3
605
Work Orders WO 59203369270
71111.18 Engineering NA-21-00056 Temporary Missile Shield for Unit 1 Containment 07/21/2021
Changes
Miscellaneous Sikaflex-1A August 2019
Product Data
Sheet
WO59203369270 Install Temp Mod NA-21 -00056 07/21/2021
71111.19 Corrective Action CR1180896 NRC identified transient combustible debris under U1 09/19/2021
Inspection Type Designation Description or Title Revision or
Procedure Date
Documents TDAFW pumphouse grating
Resulting from
Inspection
Miscellaneous Unit 2 Operator Narrative Logs (08/04/2021 to 08/31/2021)
Training Module Basic Electric Distribution
INPO 87-028 Post-Maintenance Testing December
1994
Tagout 2-21-CH- Tagout for 2-CH-P-1A, Unit 2 High Head Safety Injection 09/28/2021
007 Pump '1A'
Procedures 0-MPM-0701-04 Maintenance Run Test Procedure for Emergency Diesel 36
Generator
0-OP-26.9 4160 Volt Breaker Operation 34
1-PT-46.21 RCS Pressure Boundary Components Affected by Boric Acid 32
Accumulation
1-PT-46.21.1 Containment Boric Acid Accumulation Inspection 5
1-PT-71.1Q 1-FW-P-2, Turbine Driven Auxiliary Feedwater Pump and 74
Valve Test
2-MOP-8.01 2-CH-P-1A, A Charging Pump 64
2-PT-36.39 Operability Testing of Interlocks from Control Circuits for 7
Breaker 25J6, Charging Pump 2-CH-P-1B
2-PT-82.2A 2H Diesel Generator Test (Simulated Loos of Off-Site 78
Power)
MA-AA-100 Conduct of Maintenance 22
NCRODP18.NA Basic Electrical Distribution System 11/12/2019
OP-AA-200 Equipment Clearance 34
VPAP-2003 Post Maintenance Testing Program 14
Work Orders 59203303225
203354024
203366914
203370038
71111.20 Corrective Action CR1180743 NRC Closeout Walkdown- Unit 1 Containment
Documents
Resulting from
Inspection
Inspection Type Designation Description or Title Revision or
Procedure Date
Miscellaneous Reactor engineering reactivity plan for Unit 1 startup from 09/17/2021
maintenance outage
Startup Just-In- A operations crew startup JITT for maintenance outage 05/21/2021
Time-Training
(JITT)
Procedures 1-OP-1.3 Unit Startup from Mode 5 to Mode 4 75
1-OP-1.4 Unit Startup from Mode 4 to Mode 3 80
1-OP-1.5 Unit Startup from Mode 3 to Mode 2 94
1-OP-1C.2 Estimated Critical Position Calculation Using RXMAN Code 3
1-OP-2.1 Unit Startup from Mode 2 to Mode 1 128
71111.22 Calculations CALC 59-01-PT- 1-SI-P-1A & 1-SI-P-1B Comprehensive Pump Testing 3
138
CALC ME-0628 Minimum Delivered LHSI Flow For LB LOCA Analysis And 1 Addendum
Acceptance Criteria For LHSI Pump Operability Verification 00A
Testing, North Anna 1 & 2
Corrective Action CR1170488
Documents CR1170820
CR1176404
CR1176549
CR1176602
CR1176858
CR1176867
Miscellaneous ASME OM Code for Operation and Maintenance of Nuclear
Power Plants, Subsections ISTB and ISTC, Inservice
Testing of Pumps in Light-Water Reactor Plants
ETE-CEP-2019- Summary of Design Basis Accident Flow Rates for Pumps in 1
0005 the North Anna IST Program
NA-PLAN-000-U1 North Anna Power Station Unit 1 Inservice Testing Program 2
Plan for Pumps and Valves- Fifth Inservice Testing Interval
(December 15, 2020 - December 14, 2030)
Procedures 0-MPM-2000-01 Annual/Full Load Test of FLEX Equipment 9
1-PT-138 Valve ISI- LHSI System Functional Verification 2
ER-AA-IST-101 ASME IST Program - Inservice Testing of Pumps 5
ER-AA-IST-PMP- ASME IST Program - Inservice Testing of Pumps 10
Inspection Type Designation Description or Title Revision or
Procedure Date
101 Implementation
ER-AA-NDE-TV- IWL Visual Examination Procedure 2
606
Work Orders 59203308119 BDB Annual Inspections
71114.06 Corrective Action CR1176786
Documents
71124.02 Procedures RP-AA-103 ALARA Program Revision 2
RP-AA-103-1000 Department, Station and Fleet ALARA Committees Revision 5
RP-AA-274 Radiation Work Permits Revision 10
RP-AA-275 Radiological Risk Assessment Process Revision 5
71124.06 Corrective Action CR1161309 1-VG-RI-180 has been non-functional for 7 days 11/23/2020
Documents CR1176799 Fault on 1-VG-RM-180-1 and 180-2 07/13/2021
Miscellaneous HP-1033.206 Grab sampling due to radiation monitor #1-GW-RM-178 08/01/2021
being out of service
HP-1033.206 Grab sampling due to radiation monitor #2-SS-RM-225 being 02/24/2021
out of service
Procedures HP-3010.021 Radioactive Liquid Waste Sampling and Analysis Rev. 23
71124.07 Calibration Air Sampler Air Sampler Calibration Kit #15 03/04/2021
Records Calibration Kit
- 15
Air Sampler Air Sampler Calibration Kit #16 02/17/2021
Calibration Kit
- 16
Air Sampler Air Sampler Calibration Kit #20 02/18/2021
Calibration Kit
- 20
Air Sampler Air Sampler Calibration Kit #27 02/16/2021
Calibration Kit
- 27
O-PT-40.1 METEOROLOGICAL MONITORING SYSTEM 01/08/2019
CALIBRATION
Corrective Action CRs 1129605, Corrective Action Document Various
Documents 1131123,
1151189,
Inspection Type Designation Description or Title Revision or
Procedure Date
1154302,
1159285,
1166236, and
1166315.
Engineering NA-21-00020 Met Tower Wind Sensor Replacement 07/29/2021
Changes
Engineering NA-2020-022 CM-AA-REA-1001 - Request for Engineering Assistance: 05/20/2020
Evaluations Meteorological Monitoring
PA7642310 Met Tower F460 cup and valve parts discontinued from 07/15/2019
production
PA7933602 Met Tower annual inspection PM strategy 05/13/2020
PA8077843 Met Tower Wind Speed Sensor Obsolete 07/07/2020
PA8334529 Prep and Issue DC for REA NA-2020-022 - Met Tower 01/19/2021
Speed Sensor Obsolete
Miscellaneous 2019 2019 Interlaboratory Comparison Program Results N/A
Interlaboratory
Comparison
Program Results
2019 Joint Joint Frequency Distribution report based on the annual 03/03/2020
Frequency meteorological data collected in 2019 (includes 5 yr data
Distribution integration)
20 2020 Interlaboratory Comparison Program Results N/A
Interlaboratory
Comparison
Program Results
20 Joint Joint Frequency Distribution report based on the annual 02/04/2021
Frequency meteorological data collected in 2020 (includes 5 yr data
Distribution integration)
HP 3051.010 HP 3051.010 - Attachment 10 (Field Log: Environmental Air 08/03/2021
Sampler Stations)
Procedures 0-ACP-MM-NIS- Primary Meteorological Tower Instrument Calibration Rev. 9
001P
0-HSP-REMP- RADIOLOGICAL ENVIRONMENTAL MONITORING Rev. 2
001 PROGRAM, LAND USE CENSUS
Inspection Type Designation Description or Title Revision or
Procedure Date
0-PT-40.1 METEOROLOGICAL MONITORING SYSTEM Rev. 9
CALIBRATION
C-HP-1033.620 PORTABLE AIR SAMPLERSCALIBRATION AND Rev. 9
OPERATION
HP-3051.010 RADIOLOGICAL ENVIRONMENTAL MONITORING Rev. 33
PROGRAM
HP-3051.020 GROUND WATER PROTECTION PROGRAM Rev. 15
RP-AA-502 Groundwater Protection Program Rev. 9
VPAP-2103N Offsite Dose Calculation Manual (North Anna) Rev. 29
Self-Assessments 19-10 ODCM, ODCM, REMP, EPP Self-Assessment 01/13/2020
Assessment
2017 GWP 2017 GWP Initiative Self-Assessment (Appendix B) 12/2017
Initiative Self-
Assessment
Work Orders 59203324540 Replace Sump Pump (02-DB-P-27-PUMP) 03/09/2021
71151 Miscellaneous North Anna Heat Removal Performance Limit Exceeded
(PLE) Derivation Report (June 2020 to July 2021)
Monthly Fuel Reliability Indicator June 2021 for North Anna
Power Station
Unit 1 and 2 Heat Removal URI Derivation Reports for June Generated
20 to July 2021 08/23/2021
Max Dose Equivalent Iodine Excelsheet (from April 2020 to
June 2021)
71152 Corrective Action CR1170098
Documents CR1171597
CR1179232
CR1179360
CR1181870
Corrective Action CR1182856 NRC 3Q21 Integrated Inspection Exit Brief Items
Documents
Resulting from
Inspection
23