IR 05000338/2021012
| ML21176A056 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/25/2021 |
| From: | Scott Shaeffer Division of Reactor Safety II |
| To: | Stoddard D Virginia Electric & Power Co (VEPCO) |
| References | |
| IR 2021012 | |
| Download: ML21176A056 (12) | |
Text
June 25, 2021
SUBJECT:
NORTH ANNA POWER STATION - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000338/2021012 AND 05000339/2021012
Dear Mr. Stoddard:
On May 13, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at North Anna Power Station. On May 13, 2021, the NRC inspectors discussed the results of this inspection with Mr. Fred Mladen, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
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/
Scott M. Shaeffer, Chief Engineering Branch 2 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:
Report Numbers:
05000338/2021012 and 05000339/2021012
Enterprise Identifier: I-2021-012-0006
Licensee:
Virginia Electric and Power Company
Facility:
North Anna Power Station
Location:
Mineral, Virginia
Inspection Dates:
April 26, 2021 to May 13, 2021
Inspectors:
P. Braaten, Senior Reactor Inspector
J. Dymek, Reactor Inspector
J. Montgomery, Senior Reactor Inspector
D. Strickland, Reactor Inspector
Approved By:
Scott M. Shaeffer, Chief
Engineering Branch 2
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial fire protection 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
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000338,05000339/20 21012-01 URI 2021012-01 for North Anna Power Station Unit 1 and Unit 2. Following a fire-induced hot short stall event of NAPS CVCS MOVs, there is uncertainty whether valves' pressure boundary components would be compromised and challenge safe shutdown capability.
71111.21N.05 Open
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.
REACTOR SAFETY
===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)===
The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis (FHA) or safe shutdown analysis (SSA).
(1)a. Review deficiencies or open fire protection impairments for the selected system, including any temporary modifications, operator workarounds, or compensatory measures.
b. Verify that operator actions can be accomplished as assumed in the licensees FHA, or as assumed in the licensees fire probabilistic risk assessment (FPRA)analysis and SSA.
c. Review repetitive or similar maintenance work requests which could be an indicator of a design deficiency and could affect the ability of the components to perform their functions, when needed.
d. Ensure that post maintenance and/or surveillance activities are performed as scheduled.
e. Perform a walkdown inspection to identify equipment alignment discrepancies.
Inspect for deficient conditions such as corrosion, missing fasteners, cracks, and degraded insulation.
f. Ensure the selected SSCs that are subject to aging management review (AMR)pursuant to 10 CFR Part 54 are being managed for aging (e.g., loss of material, cracking, reduction of heat transfer) in accordance with appropriate aging management programs. Verify that the licensees aging management program activities (such as, Fuel Oil Analysis or Selective Leaching Aging Management Program) associated with FP equipment are being implemented.
g. If a review of operating experience issues will be completed for the selected inspection sample, verify that the licensee adequately reviewed and dispositioned the operating experience in accordance with their processes.
The team selected the following SSCs as samples:
- Automatic Wet Pipe Sprinkler on elev. 259' 6" of FA 11 (Auxiliary Building)
(2)
(3)
- Unit 2 Chemical Volume and Control System (CVCS)
(4)
- Unit 2 480VAC Distribution System
Fire Protection Program Administrative Controls (IP Section 03.02) (1 Sample)
The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis. If applicable, ensure that the licensees FPP contains adequate procedures to implement the selected administrative control. Verify that the selected administrative control meets the requirements of all committed industry standards.
(1)
- Combustible Control Program
Fire Protection Program Changes/Modifications (IP Section 03.03) (2 Samples)
The inspectors verified the following:
a. Changes to the approved FPP do not constitute an adverse effect on the ability to safely shutdown.
b. The adequacy of the design modification, if applicable.
c. Assumptions and performance capability stated in the SSA have not been degraded through changes or modifications.
d. The FPP documents, such as the Updated Final Safety Analysis Report, fire protection report, FHA, and SSA were updated consistent with the FPP or design change.
e. Post-fire SSD operating procedures, such as abnormal operating procedures, affected by the modification were updated.
(1)
- ETE-NA-2019-0030, Appendix R Program Implementation of SM-1841, Appendix R Emergency Switchgear Room (ESGR) Fire Natural Circulation (2)
- ETE-NA-2021-0004, Operator Manual Action Strategy for Spurious Discharge of CO2 in Cable Vault & Tunnel During ESGR Fire (1/2-FCA-2)
INSPECTION RESULTS
Unresolved Item (Open)
URI 2021012-01 for North Anna Power Station Unit 1 and Unit 2. Following a fire-induced hot short stall event of NAPS CVCS MOVs, there is uncertainty whether valves' pressure boundary components would be compromised and challenge safe shutdown capability.
URI 05000338,05000339/2021012-01 71111.21 N.05
Description:
Information Notice 92-18, Potential for Loss of Remote Shutdown Capability During a Control Room Fire, stated that fire damage could cause an electrical hot short that bypasses thermal overload protection for MOVs, and that this hot short could result in damage to the valve. North Annas technical evaluation (ETE-CME-2016-0003) demonstrated that certain MOVs in their Unit 1 and Unit 2 Chemical Volume and Control System would be locally and manually operable following a fire-induced spurious event as described in IN 92-18. Because the evaluation only considers operability of the valve following the spurious event, and not any leakage that could result from the MOVs being driven in the open or closed position, the NRC Team requested an analysis to address this aspect of IN 92-18. The licensee stated that stall thrusts generated by the spurious event are conservatively estimated high and that thrust forces generated during an actual fire-induced spurious event would be lower. Additionally, the licensee stated that based on past operating experience presented in ETE-CME-2016-0003, it had been demonstrated that valve pressure boundary components are more robust and would therefore retain their structural integrity. To make a conclusive determination, the NRC Team requested a more thorough analysis demonstrating the licensees position. In response, on 6/15/21, 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.
Planned Closure Actions: The NRC Team will review calculation 1114-0093-CALC-001, "Evaluation of North Anna Power Station (NAPS) MOV Pressure Boundaries for a Hot-Short Stall Event", to ensure licensee's evaluation adequately addresses potential for compromise of analyzed MOV pressure boundaries and resulting leakage.
Licensee Actions: The licensee has been provided follow-up questions regarding calculation 1114-0093-CALC-001. The licensee committed to addressing the provided questions and other possible follow-up inquiries following correspondence provided on 6/21/2021.
EXIT MEETINGS AND DEBRIEFS
The inspectors confirmed that proprietary information was controlled to protect from public disclosure.
- On May 13, 2021, the inspectors presented the triennial fire 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
71111.21N.05 Calculations
000-EP-0017
Combustible Loading Analysis NAPS Unit 1 & 2
Rev. 20
71111.21N.05 Calculations
ACN 7903260343
Safety Evaluation Supporting Amend 8 to License NPF-4
RE Implementation of Fire Protection Program
10/01/1979
71111.21N.05 Calculations
ACN 8611180125
Safety Evaluation Supporting Exemptions from 10 CFR 50
APP R
06/11/1986
71111.21N.05 Calculations
NAPS APP R
Report
North Anna Power Station Appendix R Report
71111.21N.05 Calculations
North Anna Power Station Updated Final Safety Analysis
Report
2/18/2021
71111.21N.05 Calculations
SDBD-NAPS-FP
System Design Basis Document for Fire Protection System
North Anna Power Station
71111.21N.05 Corrective Action
Documents
CA 7868307
3/4/2020
71111.21N.05 Corrective Action
Documents
CA 7868308
3/4/2020
71111.21N.05 Corrective Action
Documents
CR 019539
Rev. 2
71111.21N.05 Corrective Action
Documents
CR 1092157
3/15/2018
71111.21N.05 Corrective Action
Documents
CR 1150476
06/25/2020
71111.21N.05 Corrective Action
Documents
CR 1156170
09/28/2020
71111.21N.05 Corrective Action
Documents
CR 1157092
09/23/2020
71111.21N.05 Corrective Action
Documents
CR 1166332
2/23/2021
71111.21N.05 Corrective Action
Documents
CR-1129424
Rev. 0
71111.21N.05 Corrective Action
Documents
CR1170260
04/15/2021
71111.21N.05 Corrective Action
CR1170330
04/15/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
71111.21N.05 Drawings
11715-FB-104K
Carbon Dioxide Fire Protection Zone Summary Sheet NAPS
Unit 1 & 2
Rev. 2
71111.21N.05 Drawings
11715-FE-12E-11
Wiring Diagram Fire Protection LP CO2 System #2 Storage
Tank & Master Valve Drawing.
Rev. 11
71111.21N.05 Drawings
11715-FE-69A,
Sheet 1
Lighting Plan Auxiliary Building - El 244' - 6"
Rev. 18
71111.21N.05 Drawings
2050-DAR-
095B, Sheet 1
Appendix R Flowpath Chem and Volume Control System
Rev. 16
71111.21N.05 Drawings
2050-DAR-
095B, Sheet 2
Appendix R Flowpath Chem and Volume Control System
Rev. 13
71111.21N.05 Drawings
2050-DAR-
095C, Sheet 1
Appendix R Flowpath Chem and Volume Control System
Rev. 9
71111.21N.05 Drawings
2050-DAR-
096A, Sheet 1
Appendix R Flowpath Safety Injection System
Rev. 1
71111.21N.05 Drawings
2050-DAR-
096A, Sheet 3
Appendix 'R' Flowpath Safety Injection System
Rev. 1
71111.21N.05 Drawings
2050-FE-1AF
480V One Line Diagram Emergency Busses 2H, 2H1, 2J,
2J1
Rev. 18
71111.21N.05 Drawings
2050-FE-1BA
Appendix R Electrical One Line Diagram
Rev. 16
71111.21N.05 Drawings
2050-FM-304A-
Fire Barrier and Pressure Envelope Penetrations-Cable
Tray Rooms
Rev. 3
71111.21N.05 Drawings
FLHR 17517
Sheet 11 of 28
LP Cardox Fire Extinguishing Extinguishing System Storage
Tank Relay Cabinet for System 1 or System 2
Rev. A
71111.21N.05 Drawings
FLHR-17517
Sheet 18 of 28
Cardox LP Fire Extinguishing System Elementary Line
Diagram for System # 2
71111.21N.05 Engineering
Changes
DCN NA-08-0157
Unit 1 Cable Spreading Room Fire Venting
2/17/2009
71111.21N.05 Engineering
Evaluations
CM-AA-ETE-101
Determination of Combustible Loading Fire Area Status
2/15/2021
71111.21N.05 Engineering
Evaluations
CM-AA-ETE-101
Combustible Loading Analysis North Anna Power Station,
Units 1 and 2
71111.21N.05 Engineering
Evaluations
EE-0118
CFR 50 Appendix R Electrical Distribution System
Coordination Study
Rev. 4
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.21N.05 Engineering
Evaluations
EE-0395
Safety Related 480V Load Center Coordination
Rev. 6
71111.21N.05 Engineering
Evaluations
EE-0806
NAPS 4160V and 480V Short-Circuit Analysis
Rev. 2
71111.21N.05 Engineering
Evaluations
ET CEP 00-0043
Availability of MOVs for Local Operation
Rev. 0
71111.21N.05 Engineering
Evaluations
ET-N-03-004
Evaluation of Fire Door Clearances NAPS Unit 1 & 2
2/10/2003
71111.21N.05 Engineering
Evaluations
ET-N-08-0019
Evaluation of Fire Retardant Wrap Applied to Power Cables
for Charging and Component Cooling Water Wraps
04/29/2008
71111.21N.05 Engineering
Evaluations
ET-N-08-0094
Evaluation of Low Pressure CO2 System Vendor
Calculations and Blower door Test
Rev. 1
71111.21N.05 Engineering
Evaluations
ETE-CEP-00-
25
Penetration Seal Configuration Evaluations
Rev. 2
71111.21N.05 Engineering
Evaluations
ETE-CEP-2011-
0003
Appendix R Multiple Spurious Operation (MSO)
Identification and Evaluation - North Anna Units 1 and 2
Rev. 3
71111.21N.05 Engineering
Evaluations
ETE-CEP-2017-
1002
Work Control Process, License Renewal Aging
Management Activities
Rev. 0
71111.21N.05 Engineering
Evaluations
ETE-CEP2011-
1002
Fire Protection Program-License Renewal Aging
Management Program
Rev. 0
71111.21N.05 Engineering
Evaluations
ETE-CME-2016-
0003
Discussion of the Effects of Stall Thrust for Selected North
Anna Motor Operated Valves Subject to Appendix R
Concerns
Rev. 0
71111.21N.05 Engineering
Evaluations
ETE-NA-2012-
21
Additional MSO Analysis for Appendix R III.G Fire Areas
Rev. 3
71111.21N.05 Engineering
Evaluations
ETE-NA-2019-
0030
Appendix R Program Implementation of SM-1841, Appendix
R Emergency Switchgear Room (ESGR) Fire Natural
Circulation Cooldown for NAPS
Rev. 1
71111.21N.05 Engineering
Evaluations
NA-2011-0021
Evaluation of Permanently Stored Combustible Materials
Rev.8
71111.21N.05 Miscellaneous
CVCS Aging Management Review
71111.21N.05 Miscellaneous
2-96-2253-002
Commitment Document EDG Door Strength with CO2
Discharge
2/12/1996
71111.21N.05 Miscellaneous
59-C195-00002
Vendor Technical Manual
Rev. 1
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Cardox Low Pressure Carbon Dioxide Storage Units
71111.21N.05 Miscellaneous
ER-AA-AMP-10
License Renewal Aging Management Program
Rev. 4
71111.21N.05 Miscellaneous
ER-AA-AMP-101
Implementation of Activities Performed by License renewal
Aging Management Coordinators
Rev. 11
71111.21N.05 Miscellaneous
Potential For Loss of Remote Shutdown Capability During a
Control Room Fire
2/28/1992
71111.21N.05 Miscellaneous
Technical Report
LR-2143
Chemical and Volume Control System Screening Report
5/14/2002
71111.21N.05 Procedures
0-ECM-0204-02
Emergency Power to Pressurizer Vents
Rev. 0
71111.21N.05 Procedures
0-EPM-2304-02
RHR and Pressurizer Vents Appendix R Equipment
Inspection
Rev. 16
71111.21N.05 Procedures
0-FCA-0
Fire Protection - Operations Response
Rev. 22
71111.21N.05 Procedures
0-MPM-0454-21
Inspection and Preventative Maintenance of Fire Dampers
Rev. 2
71111.21N.05 Procedures
0-PT-105.1.2
Fire Door Inspection Service Building
Rev. 12
71111.21N.05 Procedures
0-PT-105.1.4D
Fire Protection System-Fire Barriers
Rev. 12
71111.21N.05 Procedures
0-PT-109.1.5
Fire Protection Auxiliary Building and Service Building Cable
Vault and Tunnel Sprinkler System Functional Tests and
Inspections
Rev. 5
71111.21N.05 Procedures
2-FCA-2
Emergency Switchgear Room Fire
Rev. 43
71111.21N.05 Procedures
2-FCA-3
Cable Vault and Tunnel Fire
Rev. 35
71111.21N.05 Procedures
2-FCA-4
Auxiliary Building Fire
Rev. 22
71111.21N.05 Procedures
CM-AA-FPA-100
Fire Protection/Appendix R (Fire Safe Shutdown) Program
71111.21N.05 Procedures
CM-AA-FPA-101
Control of Combustible and Flammable Materials
71111.21N.05 Procedures
CM-AA-FPA-102
Fire Protection and Fire Safe Shutdown Review and
Preparation Process and Design Change Process
71111.21N.05 Procedures
ER-AA-AMP-103
Scoping and Screening of License Renewal Aging
Management Components
Rev. 0
71111.21N.05 Procedures
ER-AA-AMP-104
Aging Management Review for License Renewal Systems,
Structures, and Components
Rev. 0
71111.21N.05 Procedures
ER-AA-AMP-106
Aging Management Programs for License Renewal
Systems, Structures, and Components
Rev. 0
71111.21N.05 Work Orders
2-PT-100
Appendix R Equipment and Circuitry Functional Test
Completed
10/13/2020
71111.21N.05 Work Orders
2-PT-214.15
Auxiliary Shutdown Panel Controls Verification
Completed
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
10/14/2020
71111.21N.05 Work Orders
0-PT-105.1.4.D Fire Protection System Fire Barriers
01/13/2020
71111.21N.05 Work Orders
1-PT-105.3.2 Fire Extinguisher and Hose Station Inspection
Reactor Containment
04/02/2021
71111.21N.05 Work Orders
2-PT-105.3.2 Fire Extinguisher and Hose Station Inspection
Reactor Containment
05/04/2020
71111.21N.05 Work Orders
0-PT-105.1.2 Fire Door Inspection Service Building
11/02/2020
71111.21N.05 Work Orders
2-PT-102.1 Low Pressure CO2 Total Flooding Zones
Functional Test and Puff Test
03/11/2021