IR 05000338/2021010
| ML21323A199 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/18/2021 |
| From: | James Baptist NRC/RGN-II/DRS/EB1 |
| To: | Stoddard D Dominion Energy Virginia, Virginia Electric & Power Co (VEPCO) |
| References | |
| IR 2021010 | |
| Download: ML21323A199 (20) | |
Text
November 18, 2021
SUBJECT:
NORTH ANNA POWER STATION - DESIGN BASIS ASSURANCE INSPECTION (PROGRAMS) INSPECTION REPORT 05000338/2021010 AND 05000339/2021010
Dear Mr. Stoddard:
On October 8, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at North Anna Power Station and 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.
Three findings of very low safety significance (Green) are documented in this report. Three 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.
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/
James B. Baptist, Chief Engineering Br 1 Division of Reactor Safety 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: 05000338/2021010 and 05000339/2021010 Enterprise Identifier: I-2021-010-0042 Licensee: Dominion Energy Facility: NORTH ANNA POWER STATION Location: Mineral, VA Inspection Dates: September 20, 2021 to October 08, 2021 Inspectors: P. Braxton, Reactor Inspector T. Fanelli, Senior Reactor Inspector M. Schwieg, Senior Reactor Inspector T. Su, Reactor Inspector Craig Baron, Mechanical Contractor Maty Yeminy, Mechanical Contractor Chase Franklin, Reactor Inspector ( trainee)
Approved By: James B. Baptist, Chief Engineering Br 1 Division of Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (programs) 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
Inadequate Calculation to Ensure Diesel Cooling System Met Pressure Transient Requirements Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000338,05000339/2021010-01 Open/Closed The inspectors identified a Green finding and an associated NCV of 10 CFR Part 50 Appendix B, Criterion 3, Design Control, for the licensee's failure to meet the DOM-QA-1 design verification requirements and the design control procedure requirements in calculation (USB-272, Emergency Diesel Generator Room Tornado Analysis).
Failure to scope safety related MOVs into the MOV test program Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000338,05000339/2021010-02 Open/Closed The inspectors identified a Green finding and an associated NCV of 10 CFR Part 50.55a Codes and Standards for removing safety-related Charging (CH) pump Motor Operated Valves (MOVs) from the station MOV testing program. The required scope of the program was specified by the scoping provisions in NRC Generic Letter (GL) 89-10, Safety-Related Motor-Operated Valve Testing and Surveillance Results of the Public Workshops (Generic Letter 89-10) and GL96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves (Generic Letter 96-05).
Inadequate procedure for handling age degraded safety related cable.
Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None 71111.21M Systems NCV 05000338,05000339/2021010-03 Open/Closed The inspectors identified a Green finding and an associated NCV of 10 CFR Part 50 Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the licensees failure to include work instructions to ensure the safety function of aged cables during and after handling.
Additional Tracking Items
None.
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), inspectors were directed to begin telework. In addition, 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
===71111.21M - Design Bases Assurance Inspection (Teams) The inspectors evaluated the following components and listed applicable attributes, permanent modifications, and operating experience:
Design Review - Risk-Significant/Low Design Margin Components (IP Section 02.02) (9 Samples)
- Compliance with UFSAR, Technical Specifications (TS), and TS Bases
- Conformance with manufacturer instructions for installation, maintenance, and operation
- Material condition and configuration (i.e. walkdown of area)
- System health reports
- Design requirements
- Operating Environment
- Maintenance and preventive maintenance effectiveness
- (2) Unit 1 - Diesel Driven Fire Pump System (01-FP-P-2-PUMP, 01-FP-P-2-ENGINE)
- Design bases documents, system descriptions, and training documents
- Primary design calculations
- Normal and Emergency Operating Procedures
- Surveillance Test Procedures and Recent Results
- Material Condition of Pump and Associated Equipment
- Vendor Manuals for Engine and Pump
- Corrective Action History
- Condition reports associated with component
- (3) Unit 1 CCW Heat Exchanger
- Reviewed heat Exchanger procurement specification
- Reviewed heat Exchanger data sheet
- Reviewed maximum allowed fouling factor
- Reviewed maximum number for plugged tubes
- Reviewed list of system & component CRs since last DBI. Review for Potential issues. Recorded in system health reports?
- Reviewed GL 89-13 program plan
- Reviewed licensee response letter(s) to GL 89-13
- Reviewed completed surveillance test for the Heat Exchanger. Reviewed test set up and instrument uncertainty (compare the energy removed from the hot medium to the energy added to the cold medium).
- Reviewed acceptance Criteria values
- (4) Service Water Valve House (Settling)
- Assess methodology for setting the monuments
- Assess validity of benchmarking
- Reviewed settling trend.
- Reviewed the method North Anna used to release all stresses
- (5) Uni1 and Unit 2 EDG Sequencers
- Design bases documents, system description
- Primary design calculations
- Surveillance Test Procedures Recent Results
- Preventative Maintenance Procedures
- Vendor Manuals
- Corrective Action History
- Condition reports associated with component
- (6) Unit 1 DC System Switchgear
- Design bases documents, system description
- Primary design calculations
- Surveillance Test Procedures
- Preventative Maintenance Procedures
- Vendor Manuals for the Sequencer
- Corrective Action History
- Condition reports associated with component
- (7) Offsite Power (1E and non-1E) and High-Voltage Switchyard
- Design bases documents, system description
- Primary design calculations
- Surveillance Test Procedures Recent Results
- Preventative Maintenance Procedures
- Vendor Manuals for RSST
- Engineering design changes
- Corrective Action History
- Condition reports associated with component
- (8) Unit 1 Motor-Operated Valves MOV 1863 A/B, MOV-1267 A/B, 1269 A/B, 1270 A/B, and associated check valves
- Normal and Emergency Operating Procedures
- Surveillance Test Procedures and Recent Results
- Inservice Test Procedures and Recent Results
- Setpoint for Automatic Opening of Valves MOV 1863 A/B
- MOV Program Scoping
- Material Condition of Valves and Associated Equipment Corrective Action History
- (9) Unit 1 & 2 Flex Equipment, Including Portable Diesel Generators[List sampled component with description/number (e.g., Essential 4.16kV Switchgear EH12)
- Licensing Commitments associated with FLEX Equipment
- Operating Procedures for Extended Station Blackouts
- Maintenance and Testing of FLEX Equipment
- Method of Delivering Fuel Oil to FLEX Equipment
- Storage of FLEX Equipment
- Corrective Action History Design Review - Large Early Release Frequency (LERFs) (IP Section 02.02) ===
- (1) NA-21-00056, Temporary Missile Shield for Unit 1 Containment, Rev. 0
- Quality of installation
- Quality Assurance
- Reviewed critical parameters
- Reviewed component procurement specifications
- Reviewed vendor certified fuel oil pump Head Capacity curves
- Reviewed pump NPSH curve
- Reviewed vendor manuals for components
- Reviewed equipment assembly drawings with Bill of Materials
- Reviewed system normal operating procedure
- Reviewed system abnormal operating procedure
- Reviewed IST procedures for pumps and check valves
- Reviewed IST acceptance criteria
- Reviewed completed IST procedures
- Reviewed system health report - last quarter
- Reviewed protection from Tornado missiles
- Reviewed protection from Tornado under-pressure
- Verified day tank design pressure, vents and relief valves
- Reviewed check valves boundary between safety and non-safety equip
- Verified motor environment
- Verified motor HP
Modification Review - Permanent Mods (IP Section 02.03) (5 Samples)
- (1) NA-17-00248-05, Vital Bus 2-1, 2-II, 2-III and 2-IV Non-Safety Branch Circuit Fuse Installation
- (2) NA-19-00122-02, Remove Input From Loop Stop Valve Cabinet
- (3) NA-13-01190, Reserve Station Service Transformer "A" and "B" Replacement
- (4) DCP 96-106, Install Pressure Equalizing Line/ NAPS/ Unit 2, 05/15/96
Review of Operating Experience Issues (IP Section 02.06) (3 Samples)
- (1) IN2016-09, Recent Issues Identified When Using Reverse Engineering Techniques in the Procurement of Safety-Related Components
- (2) IN 2020-02 FLEX Diesel Generator Operational Challenges
- (3) IN 2021-01 Lessons Learned from U.S. Nuclear Regulatory Commission Inspections of Design-Basis Capability of Power-Operated Valves at Nuclear Power Plants
INSPECTION RESULTS
Inadequate Calculation to Ensure Diesel Cooling System Met Pressure Transient Requirements Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000338,05000339/2021010-01 Open/Closed The inspectors identified a Green finding and an associated NCV of 10 CFR Part 50 Appendix B, Criterion 3, Design Control, for the licensee's failure to meet the DOM-QA-1 design verification requirements and the design control procedure requirements in calculation (USB-272, Emergency Diesel Generator Room Tornado Analysis).
Description:
The team reviewed calculation USB-272, Rev 0, "Emergency Diesel Generator (EDGR) Room Tornado Analysis," to determine the diesel cooling system response to a tornado event and verify whether it met the licensees Quality Assurance (QA)requirements. The purpose of the calculation stated, to determine the design basis transient pressure response of the Emergency Diesel Generator Room (EDGR) for the tornado event.
The transient velocity, density, and differential pressure on the components in the air exhaust flow path will be determined.
The team noted that the design of the EDGR components were determined by walkdowns to be used in the calculation. The calculation modeled the radiator and fan as thick-walled orifices instead of the actual design, which was a flat-tube and plate (fin) radiator six inches thick with 858 tubes arranged in six staggered layers of tubes forming a tortuous air path for increased heat transfer. It did not describe the details of the as-installed design of the radiator and the fan, but it did estimate how much blockage each caused to the respective flow path to estimate the diameter of the thick-walled orifice model. The calculation underestimated the blockage caused by the radiator because the walkdown misidentified the radiator tube blockage as only ten percent of the total blockage (see radiator design above). Additionally, the analysis did not identify the acceptance criteria for maximum loading to be applied to the radiator or axial fan to which the analysis results were to be compared. The EDGR room inlet dampers can be open letting in full air flow causing high dynamic pressures through these components which was not evaluated in the calculation. The calculation evaluated the barometric pressure drop from the tornado (-3 psi) but it did not evaluate the dynamic pressures developed from air flow through and across the radiator (tortuous path through small diverging apertures) or the fan blades (airfoils) that could cause damage.
The team determined that the calculation did not suitably model the potential tornado pressure responses for the radiator or axial fan, and thus did not meet the purpose stated in the calculation. The team noted that the licensees referenced technical handbook discussed mathematical models for staggered flat-tube and plate radiator with six tube layers and axial fans, (Handbook of Hydraulic Resistance, I.E. Idel'Chik, 1960).
The Quality Assurance Program Documents (DOM-QA-1) design control Section 3.2.3, Design Verification, states, in part, that the design control program ensures that appropriate verification methods are used, the appropriate design parameters are chosen, the acceptance criteria are identified, the verification is satisfactorily accomplished, and the results are properly recorded. The administrative design control procedure for engineering calculations (CM-AA-CLC-301), Attachment 1, Fundamental Expectations specifies, in part, that calculations shall provide technically correct results that meet the objectives stated in the Purpose section of the calculation. The team determined that the calculation did not meet the QA requirements prescribed in DOM-QA-1 or the calculation design control procedure.
Corrective Actions: In response to the inspectors concerns, the licensee-initiated condition report CR1182226 on October 8, 2021 and CR1183893 on October 26, 2021 to correct the tornado analysis.
Corrective Action References: CR1182226, CR1183893
Performance Assessment:
Performance Deficiency: The inspectors determined that the calculation (USB-272, Emergency Diesel Generator Room Tornado Analysis) failed to meet the DOM-QA-1 design verification requirements and the design control procedure requirements, which was a performance deficiency. The calculation did not suitably identify the as-installed design of the EDG radiator and EDG fan. It did not model the EDG room configurations pertinent to both the static and dynamic pressure responses. Nor did it use appropriate mathematical models or appropriate acceptance criteria for the radiator and cooling fan during tornado events. Based on this, the analysis did not meet the QA requirements and stated purpose of the calculation.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control 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 failure to adequately verify the performance of the EDG cooling system during tornado events affected the availability and reliability of the emergency power system when needed during external events and a loss of offsite power.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. A risk evaluation was performed by a regional senior reactor analyst using SAPHIRE Version 8.2.5 and NRC North Anna SPAR model Version 8.56. The conditional analysis assumed failure of the EDGs and operator recovery actions for all tornado initiating events with a one-year exposure time. The dominant sequences involved a tornado initiator accompanied by a loss of offsite power with failures of the emergency diesel generators, FLEX equipment and operator actions to recover offsite power. The analysis determined that the estimated increase in core damage frequency was less than 1E-06/year and did not involve sequences associated with an increase in large early release frequency, representing a finding of very low safety significance (Green).
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: 10 CFR 50, Appendix B, Criterion 3, Design Control, that states, in part, that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program Design control measures shall be applied to items such as the following: reactor physics, stress, thermal, hydraulic, and accident analyses; and the delineation of acceptance criteria for inspections and tests.
Contrary to Criterion 3, since 1/7/1992 the site failed to provide design control measures for verifying or checking the adequacy of the diesel cooling system during design such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program, and failed to apply design control measures to items such as analyses for design basis pressure responses; and the delineation of acceptance criteria for inspections and tests of the EDG cooling system.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to scope safety related MOVs into the MOV test program Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000338,05000339/2021010-02 Open/Closed The inspectors identified a Green finding and an associated NCV of 10 CFR Part 50.55a Codes and Standards for removing safety-related Charging (CH) pump Motor Operated Valves (MOVs) from the station MOV testing program. The required scope of the program was specified by the scoping provisions in NRC Generic Letter (GL) 89-10, Safety-Related Motor-Operated Valve Testing and Surveillance Results of the Public Workshops (Generic Letter 89-10) and GL96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves (Generic Letter 96-05).
Description:
The inspectors reviewed Engineering Transmittal (ET)-CME-07-0003, Justification for Removal of CH Pump Suction Valves from the Scope of the NAPS MOV Program, Rev. 0, approved on May 23, 2007. The ET evaluation included Unit 1 valves 1-CH-MOV-1267A/B, 1-CH-MOV-1269A/B, 1-CH-MOV-1270A/B and Unit 2 valves 2-CH-MOV-2267A/B, 2-CH-MOV-2269A/B, 2-CH-MOV-2270A/B. The ET reviewed the Inservice Testing (IST) basis document, the Updated Final Safety Analysis Report (UFSAR), and Emergency Operating Procedures (EOPs). Because the MOVs were not identified in the documents to establish alternate flow paths for any events, the licensee determined that they did not perform a safety related function. Based on this, the MOVs were removed from the MOV test program on January 15, 2008, with Addendum No. 2 to Technical Report EP-0020, Engineering Position and Technical Overview for Generic Letter 96-05 - Periodic Verification of Design-Basis Capability of Safety Related Motor Operated Valves, Rev. 0.
The inspectors noted that the EOPs did not identify every alternate flow path for every emergency condition. The inspectors identified that station operators could use these MOVs in response to certain emergency conditions based on applicable maintenance operating procedures to isolate a portion of the system during the long-term phase of an accident. For example, procedure 1-MOP-8.01, 1-CH-P-1A - A Charging Pump, Revision 67 directed that valves 1-CH-MOV-1267A and 1267B be closed from the control room to isolate the unit 1 A charging pump. The inspectors determined that these MOVs had a safety related function to establish an alternate flow path for certain events such as charging pump seal failures.
Corrective Actions: In response to the inspectors concerns, the licensee-initiated condition report CR1181633 on September 29, 2021. On October 26, 2021, the licensee approved prompt operability determination (OD) CA 8587871 to address reasonable assurance of operability of these motor operated valves. The OD concluded that these valves were non-conforming due to their removal from the site MOV program but were considered operable. The OD also included the results of an evaluation performed to ensure the valves ability to close under the most limiting differential pressure.
Corrective Action References: CR1181633 CA 8587871
Performance Assessment:
Performance Deficiency: The failure include safety related MOVs in the scope of the testing program as required by GL89-10 and GL96-05 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 failure to ensure that MOV performance was in accordance with the MOV testing program affected the reliability of the ECCS system in the event of a passive failure after an accident.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, the finding was determined to be of very low safety significance because it was a design deficiency confirmed not to result in a loss of operability.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: 10 CFR Part 50.55a(b)(3)(ii), Motor-Operated Valve Testing, requires, in part, that licensees comply with the provisions for testing MOVs in ASME OM Code, ISTC 4.2, 1995 Edition with the 1996 and 1997 Addenda, or ISTC-3500, 1998 Edition through the latest edition and addenda incorporated by reference in paragraph (a)(1)(iv) of 10 CFR 50.55a, and establish a program to ensure that MOVs continue to be capable of performing their design basis safety functions. 10 CFR 50.55a(b)(3)(ii) also requires that licensees implementing ASME OM Code, Mandatory Appendix III, Preservice and In-service Testing of Active Electric Motor Operated Valve Assemblies in Light-Water Reactor Power Plants, of the 2009 Edition, 2011 Addenda, and 2012 Edition shall comply with specific conditions.
Contrary to 50.55a(b)(3)(ii), since 2008, the licensee failed to include the subject MOVs in a testing program to ensure they could perform their design basis safety function.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Inadequate procedure for handling age degraded safety related cable.
Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None 71111.21M Systems NCV 05000338,05000339/2021010-03 Open/Closed The inspectors identified a Green finding and an associated NCV of 10 CFR Part 50 Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the licensees failure to include work instructions to ensure the safety function of aged cables during and after handling.
Description:
Based on the walkdown pictures. For Unit 1 safety related battery 1-2, the cables terminated on the negative post of Cell 60 exceeded the bend radius of 3.52. The cable involved was 250 MCM Aluminum Triplex 600 V NGP-07 cable. The measured cable radius was 1.75. The inspectors noted that bend radii was exceeded on multiple safety related batteries around the plant. The Unit 2 safety related battery 2-II and the 1H diesel generator battery exceeded the minimum bend radii.
The inspectors determined that these cables in question were the original cables from initial installation more than 40 years old. Because aging can cause degradations that can damage insulation during handling such as micro fracturing, the inspectors reviewed work order (WO)to determine the work practices established to ensure the safety function of the cables during and after handling. The inspectors noted that the WO disassembled the batteries and storage racks from the room and then reassembled them. The cables could not be removed from the room as they went to a floor penetration to switchgear below. No work instruction concerning the handling of aged cables or minimum bend radii were included in the WOs to ensure the safety function of the cables during and after handling.
Corrective Actions: The licensee entered this into the corrective action program to determine the condition of the cables and correct the deficiency.
Corrective Action References: CR1181138, CR1181190
Performance Assessment:
Performance Deficiency: The failure to include work instructions to ensure the safety function of aged cables during and after handling was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality 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 failure to ensure the safety function of the safety related cables failed to ensure their reliability and capability of safety related battery systems.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, the finding was determined to be of very low safety significance because it was a design deficiency confirmed not to result in a loss of operability.
Cross-Cutting Aspect: None
Enforcement:
Violation: 10 CFR 50, Appendix B criterion V, Instructions, Procedures, and Drawings states in part that instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to the above, since 2019 the site failed to include appropriate quantitative acceptance criteria in instructions and procedures to ensure the safety function of aged cables during and after handling.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 8, 2021, the inspectors presented the The team performed exit meeting inspection results to Fred Mladen - Site VP and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.21M Calculations 11715-ES-103 LHSI Pump NPSH Rev. 0
71111.21M Calculations 12050-ES-220 Containment Floor Volume with Respect to Elevation, Addendum Rev. 0
H
71111.21M Calculations 13075.49-ES- Maximum Sump Water Level - Final NPSH Modification, Rev. 2
194 Addendum H
71111.21M Calculations 19096.0510-E-4 125V DC MAXIMUM VOLTAGE ANALYSIS (CLASS IE BUSES) Rev. 0
71111.21M Calculations CALC 59-01- Valve Inservice Inspection Rev. 4
PT-213.8A
71111.21M Calculations CALC 59-01- Valve Inservice Inspection Rev. 3
PT-213.8B
71111.21M Calculations CALC 59-02- Valve Inservice Inspection Rev. 4
PT-213.8A
71111.21M Calculations CALC 59-02- Valve Inservice Inspection Rev. 3
PT-213.8B
71111.21M Calculations CE- 1559 Containment Liner & Concrete Parametric Study Addendums A, Rev. 0
C, and D
71111.21M Calculations EE-0008 North Anna Voltage Profiles Rev. 3
71111.21M Calculations EE-0008 North Anna Voltage Profiles Rev. 3
71111.21M Calculations EE-0009 125 Vdc System Analysis Rev. 2
71111.21M Calculations EE-0025 North Atlanta Station Electrical Load List Rev. 4
71111.21M Calculations EE-0027 Emergency Diesel Generator Load Sequencing Rev. 3
71111.21M Calculations EE-0395 Safety Related 480V Load Center Coordination Rev. 6
71111.21M Calculations EE-0806 NAPS 4160V and 480V Short Circuit Analysis Rev. 2
71111.21M Calculations EE-0845 4160V and 480V Emergency Buses- Voltage Drops to Rev. 0
Switchgear DC COntrol Circuit Components
71111.21M Calculations EEE-0500 Motor Terminal Voltage for Motor Operated Valves Addendums Rev. 6
A and B
71111.21M Calculations ET-N-06-0043 Evaluation of Emergency Diesel Generator Ambient Room Rev. 1
Temperature
71111.21M Calculations ME-0314 Maximum Differential Pressure, High Pressure Safety Injection Rev. 0
and Auxiliary Feedwater Valves
71111.21M Calculations ME-0492 Thrust Band Calculation for North Anna Safety Related Motor Rev. 1
Inspection Type Designation Description or Title Revision or
Procedure Date
Operated Valves, Addendums 1 and 1A
71111.21M Calculations ME-0595 NAPS Fire Pumps Hydraulic Model 0
71111.21M Calculations ME-0700 MOV Differential Pressure (DP) Calculation for the Subject Rev. 0
Valves
71111.21M Calculations ME-0792 Fire hose station design calculation 0
71111.21M Calculations ME-3069 JOG Calculation of Required Thrust Settings for MOV 1-Sl-MOV- Rev. 2
1863A
71111.21M Calculations ME-3070 JOG Calculation of Required Thrust Settings for MOV 1-SI-MOV- Rev. 2
1863B
71111.21M Calculations ME-3200 JOG Calculation of Required Thrust Settings for MOV 2-SI-MOV- Rev. 2
2863A
71111.21M Calculations ME-530 Component Cooling Heat Exchanger Tube Plugging Study Rev. 0
71111.21M Calculations NA-Calc-ZZZ- Emergency Diesel Generator Room and Battery Area Rev. 1
01040.4910-M-1 Temperature Profile
71111.21M Calculations NA-CALC-ZZZ- Fuel Oil System 03/11/1978
11715-12050-
7.1-FO-3
71111.21M Calculations SM-1176 Impact of Maintaining NA Automatic RMT Setpoint at 19.4% Rev. 1
RWST Level, Addendum A
71111.21M Calculations SM-1511 Design Inputs for GOTHIC Containment Analysis for NA Power Rev. 1
Station
71111.21M Calculations US(B)-272 Emergency Diesel Generator Room Tornado Analysis Rev. 0
71111.21M Calculations ZZZ- Fire Pumps 0
11715_12050-
7.1-FP-2
71111.21M Corrective CR3052285, CR3052405, CR3064396, CR7616236,
Action CR7618752, CR7707420, CR7866652, CR8467896,
Documents CR1177118, CR1177264, CR1003896, CR0361181,
CR0358809, CR0356650, CR1149511, CR1162288,
CR1166642, CR1172946, CR1175367
71111.21M Corrective CR1175367 NRC Identified: Cracked cable jackets on RSST overhead cables
Action
Documents
Resulting from
Inspection Type Designation Description or Title Revision or
Procedure Date
Inspection
71111.21M Corrective CR1181038 NRC DBAI inspector noticed a typographical error on CALC EE- 9/21/2021
Action 0009
Documents
Resulting from
Inspection
71111.21M Corrective CR1181138 NRC DBAI Inspector noted a incorrect bend radius on Battery 1- 9/22/2021
Action 2
Documents
Resulting from
Inspection
71111.21M Corrective CR1181190 Incorrect bend radius on cable in the 2-II Battery Room 9/23/2021
Action
Documents
Resulting from
Inspection
71111.21M Corrective CR1181493 DBAI Inspector noted improvements needed in CALC EE-0009 9/28/2021
Action
Documents
Resulting from
Inspection
71111.21M Drawings 11715-FB-035A Fuel Oil Lines Rev. 44
71111.21M Drawings 11715-FB-41A Flow Diagram Fire Protection and Domestic Water 37
71111.21M Drawings 11715-FB-41B Valve Operating Numbers Fire Protection & Domestic Water 55
71111.21M Drawings 11715-FB-4B Yard Fuel Oil Lines Sh. 2 Rev. 17
71111.21M Drawings 11715-FB-9A Floor Drainage Auxiliary Building Sh-1 01/17/1990
71111.21M Drawings 11715-FC-24B- Plan EL 244' Outline Sh 1 Auxiliary Building 12
71111.21M Drawings 11715-FV-56A- Underground Fuel Oil Storage Tanks 1-EG-TK-2A & 2B Rev. 8
71111.21M Engineering 03-122 Emergency Generator Load Sequencing Timer Replacements 3/30/2004
Changes /NAPS /Unit #2
71111.21M Engineering NA-13-01190 Reserve Station Service Transformer "A" and "B" Replacement 23
Changes
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.21M Engineering NA-14-00022 Spare Conductors of RSST A to Transfer Bus "D' Due to 04/04/2014
Changes Damaged Insulation
71111.21M Engineering NA-15-00061 Installation of Voltage Unbalance Protection (1H) 06/06/2017
Changes
71111.21M Engineering NA-16-01034 Reserve Station Service Transformer C Replacement 7
Changes
71111.21M Engineering NA-17-00214 Diesel Driven Fire Pump (1-FP-P-2) Appendix R Fused Circuit 0
Changes Protection
71111.21M Engineering NA-19-00122 Remove Input from Loop Stop Valve Cabinet Rev. 2
Changes
71111.21M Engineering GOTHIC NAPS EDG Room Louver dP during Tornado - Normal Exhaust 9/28/2021
Evaluations Evaluation 1 Fan and EDG OFF
71111.21M Engineering GOTHIC NAPS EDG Room Louver dP during Tornado - Normal Exhaust 9/29/2021
Evaluations Evaluation 2 Fan and EDG OFF with dirtier radiator
71111.21M Engineering GOTHIC NAPS EDG Room Louver dP during Tornado - Normal Exhaust 9/29/2021
Evaluations Evaluation 3 Fan and EDG Running
71111.21M Miscellaneous Dominion- Virginia Power North Anna Environmental Zone Rev. 28
Description, Units 1 & 2
71111.21M Miscellaneous 59-G533-00080 Installation, Operation and Maintenance Manual - Power 2
Transformers
71111.21M Miscellaneous 59-N104-00005 Klockner Moeller 100 Series Motor Control Center Cubicles Rev. 9
71111.21M Miscellaneous 59-R217-00004 Load Tap Changer Type RMV-II 1500A/2000A/2500A VACUTAP 1
71111.21M Miscellaneous DNES-VA-EEN- Design Standard for Cable Rev. 1
0002
71111.21M Miscellaneous GC Cable Install GC Cable Install Manual Rev. 9
Manual
71111.21M Miscellaneous MODULE STATION DIESEL GENERATOR SYSTEMS 04/15/2020
NCRODP-55-
NA
71111.21M Miscellaneous MS-AA-PTE- Commercial Grade Dedication Rev. 10
401-1004
71111.21M Miscellaneous NA-220/1220 Procurement Specification Emergency Diesel Generator Sets Rev. 3
71111.21M Miscellaneous NA-SPEC-000- Specification for miscellaneous Vertical Sump Pumps 10/05/1970
NAS-0087A
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.21M Miscellaneous NA-VTM-000- Cummins Diesel NH/NT/NTA 855 C.I.D. Engines 4
59-C550-00001
71111.21M Miscellaneous NA-VTM-000- H, NH, NT Series Operations & Maintenance Manual 4
59-C550-00002
71111.21M Miscellaneous NA-VTM-000- Vertical Turbine Pumps Open Lineshaft Construction 3
59-P276-00001
71111.21M Miscellaneous NAS-227 Procurement Specification, Fuel Oil Pumps Rev. 2A1
71111.21M Miscellaneous NAS-96 Procurement Specification Component Cooling Water Heat Rev. 2A1
Exchangers
71111.21M Miscellaneous SDBD-NAPS- System Design Basis Document for Component Cooling System Rev. 20
71111.21M Miscellaneous SDBD-NAPS- SYSTEM DESIGN BASIS DOCUMENT FOR 125 VDC Rev. 19
ED EMERGENCY POWER SYSTEM
71111.21M Miscellaneous SDBD-NAPS- SYSTEM DESIGN BASIS DOCUMENT FOR EMERGENCY Rev. 20
EG DIESEL GENERATOR SYSTEM
71111.21M Miscellaneous SDBD-NAPS- SYSTEM DESIGN BASIS DOCUMENT FOR EMERGENCY Rev. 20
EV POWER AND VITAL BUS (120-240V) SYSTEM
71111.21M Miscellaneous SDBD-NAPS- SYSTEM DESIGN BASIS DOCUMENT FOR FIRE 20
FP PROTECTION SYSTEM
71111.21M Miscellaneous SDBD-NAPS- System Design Basis Document for Service Water System Rev. 28
71111.21M Procedures 0-AP-10 LOSS OF ELECTRICAL POWER Rev. 94
71111.21M Procedures 0-AP-10 LOSS OF ELECTRICAL POWER Rev. 94
71111.21M Procedures 0-AP-8 RESPONSE TO GRID INSTABILITY Rev. 14
71111.21M Procedures 0-MCM-0107-02 REPAIR OF DIESEL-DRIVEN FIRE PUMP 1-FP-P-2 AND 8
MOTOR-DRIVEN FIRE PUMP 1-FP-P-1
71111.21M Procedures 0-MPM-0107-01 DIESEL FIRE PUMP PREVENTIVE MAINTENANCE 23
71111.21M Procedures 0-MPM-0107-01 DIESEL FIRE PUMP PREVENTIVE MAINTENANCE 23
71111.21M Procedures 0-MPM-0107-02 DIESEL FIRE PUMP HOSE REPLACEMENT 3
71111.21M Procedures 0-PT-100.1.2 DIESEL-DRIVEN FIRE PROTECTION PUMP 1-FP-P-2 25
EXERCISE
71111.21M Procedures 1-LOG-6E OUTSIDES LOG 117
71111.21M Procedures 1-OP-26.1 TRANSFERRING 4160-VOLT BUSSES 43
71111.21M Procedures 1-PT-142.9A.1 Valve Inservice Inspection Associated with 1-EG-TK-IH FOR 1- Rev. 42
Inspection Type Designation Description or Title Revision or
Procedure Date
EG-254
71111.21M Procedures 1-PT-80.2 TESTING OF THE EMERGENCY BUS ALTERNATE POWER 6
SUPPLY
71111.21M Procedures 1-PT-81.1A Emergency Diesel Generator Fuel Oil Transfer Pumps 1EP-P- Rev. 26
1HA and 1EP-P-1HB
71111.21M Procedures 1-PT-83.3A LOAD SEQUENCING TIMERS VERIFICATION TEST Rev. 1
71111.21M Procedures 1-PT-83.3B LOAD SEQUENCING TIMERS VERIFICATION TEST Rev. 0
71111.21M Procedures 2-LOG-6F UNIT 2 SAFEGUARDS LOG 134
71111.21M Procedures MS-AA-PTE- Procurement Technical Evaluation Determination Rev. 17
401
71111.21M Procedures O-PT-100.2 FIRE PROTECTION PUMPS ANNUAL TESTING 28
71111.21M Work Orders 59102428535 FOPH Strainer Inspection/Cleaning 02-EG-2HA-Filter 02/30/20
71111.21M Work Orders 59203307849,
203307881,
203308857,
203324848,
203355689,
203365694,
203136470,
203275091,
203275093,
203275095,
203284437,
203284472,
203284473,
203284475,
203284476,
59303284493,
203284532,
59102126128,
59102948061,
59102126136
17