IR 05000338/2023003
| ML23317A265 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/13/2023 |
| From: | Matthew Fannon NRC/RGN-II |
| To: | Carr E Dominion Energy Co |
| References | |
| IR 2023003 | |
| Download: ML23317A265 (1) | |
Text
SUBJECT:
NORTH ANNA POWER STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000338/2023003 AND 05000339/2023003
Dear Eric S. Carr:
On September 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at North Anna Power Station, Units 1 and 2. On October 30, 2023, the NRC inspectors discussed the results of this inspection with Lisa Hilbert, 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, Matthew S. Fannon, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 05000338 and 05000339 License Nos. NPF-4 and NPF-7
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000338 and 05000339
License Numbers:
Report Numbers:
05000338/2023003 and 05000339/2023003
Enterprise Identifier:
I-2023-003-0020
Licensee:
Dominion Energy
Facility:
North Anna Power Station, Units 1 and 2
Location:
Mineral, VA
Inspection Dates:
July 01, 2023, to September 30, 2023
Inspectors:
K. Carrington, Senior Resident Inspector
J. Hickey, Senior Project Engineer
B. Kellner, Senior Health Physicist
D. Ray, Reactor Inspector
J. Rivera, Health Physicist
M. Schwieg, Senior Reactor Inspector
D. Turpin, Resident Inspector
Approved By:
Matthew S. Fannon, Chief
Reactor Projects Branch 4
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at North Anna Power Station, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
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 23003-01 Moisture Intrusion Resulting in Station Blackout (SBO)
Radiator Fan Motor Issues 71111.12 Open
PLANT STATUS
Unit 1 began the inspection period operating at or near 100 percent rated thermal power (RTP). On September 23, the unit was down powered to 71 percent RTP to support maintenance on an offsite transmission line. On September 24, the unit was shut down from 71 percent RTP for repairs on a letdown control valve. The unit was returned to 100 percent RTP on September 27, and remained at or near rated thermal power through the end of the inspection period.
Unit 2 began the inspection period operating at or near 100 percent RTP. On September 10, the unit was shut down for refuel outage 2R29. The unit remained shut down through the end of the 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 performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather including hot weather on August 21, 2023, and a tropical storm on September 22-23, 2023.
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 quench spray system prior to 'A' quench spray system test, on July 12, 2023
- (2) Unit 1 'J' emergency diesel generator while in protected train status, on July 14, 2023
- (3) Unit 2 outside recirculation spray system prior to 'B' casing cooling pump test, on July 19, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 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) Fire Area 2, Unit 1 and Unit 2, main control room, on July 15, 2023
- (2) Fire Area 8B, Unit 1 and Unit 2, turbine building lubricating oil room, on July 15, 2023
- (3) Fire Area 3-1, Zone Z-27-2, Unit 1, motor generator set house, on July 18, 2023
- (4) Fire Area 11, Zones Z-11-1a and Z-11-2a, Unit 1 and Unit 2, component cooling pumps, on July 19, 2023
- (5) Fire Area 11, Unit 1 and Unit 2, auxiliary building, elevation 291' and 262', on September 7, 2023
- (6) Fire Area 1-2, Unit 2 containment annulus, all elevations, on September 14, 2023
===71111.08P - Inservice Inspection Activities (PWR) The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from September 18, 2023, to September 22, 2023.
PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01)===
The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:
- (1) Ultrasonic Examinations
- 2-SI-91 Weld No. 34
- SW-81 Flange to Pipe Magnetic Particle Examinations
- 2-RC-E-2, Pressurizer Skirt Weld Welding Activities
- Replace 02-SI-MOV-2869B-Valve PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)
The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:
(1)
- 1-CH-P-2C-Pump, 2C boric acid transfer pump evaluation
- 2-CH-PI-1105B, boric acid transfer pump discharge isolation valve evaluation
- Walkdown of containment levels 291, 264, and 241 and auxiliary building on September 19, 2023
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)
- (1) The inspectors observed and evaluated licensed operator performance in the main control room during the Unit 2 shutdown for refuel outage 2R29, on September 10, 2023.
- (2) The inspectors observed and evaluated licensed operator performance in the main control room during the Unit 1 shutdown using the excess letdown system, on September 24, 2023.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)
- (1) The inspectors observed and evaluated just-in-time training for the Unit 2 refueling outage, on September 7, 2023.
- (2) The inspectors observed and evaluated just-in-time training associated with Unit 1 operations using excess letdown and shutdown, on September 23, 2023.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance by reviewing the following events and/or documents to ensure structures, systems, and components (SSCs) remained capable of performing their intended functions:
- (1) Maintenance rule functional failure review of the following condition reports (CRs)covering the period July 1, 2022 - June 30, 2023:
- CR1204718, 2-SW-TIC-202A, U2 'A' Charging Pump Service Water Flow Control Valve is Failed Low
- CR1205119, 1-HV-F-70A Found Tripped with the Breaker Closed
- CR1210963, 1-MS-PCV-101A Indicates Full Open Locally
- (2) Periodic evaluation (September 1, 2021 - March 1, 2023)
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the accuracy and completeness of the following risk assessments for planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 1 online risk during Unit 1 condensate storage tank maintenance, Unit 1 train 'B' relay surveillance, and Unit 1 'B' low head safety injection pump quarterly surveillance, on August 23, 2023
- (2) Unit 1 and Unit 2 online risk during transmission owner-issued hot weather alert, Unit 2 condensate pump swap during auxiliary feedwater system maintenance, and Unit 1 turbine driven auxiliary feedwater pump comprehensive test, the week of September 4, 2023
- (3) Unit 2 shutdown risk during Unit 2 shutdown for refueling outage 2R29 and mode transition, on September 11, 2023
- (4) Unit 2 shutdown risk during Unit 2 lowered inventory, on September 12, 2023
- (5) Unit 1 and Unit 2 online/shutdown risk during the loss of an offsite transmission line and Unit 1 emergent down power, on September 23-24, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) CR1232831, Unit 1 terry turbine exhaust fan damper making noise, on July 10, 2023
- (2) CR1233514, technical support center filter 1-HV-FL-100 failed bypass leakage test per 0-PT-77.9, on July 19, 2023
- (3) CR1233087, work order generation for inspection of control room chiller service water outlet header isolation valve 1-HV-MOV-113C diagnostic trace anomaly, on July 21, 2023
- (4) CR1238686, loss of 576 offsite transmission line and licensee entry and retraction into Technical Specification 3.8.1 action statement, on September 29, 2023
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Design Change, NA-17-00149, Station Battery Chargers 1-I, 1-II, and 1C-II Replacement, on July 22, 2023
- (2) Engineering Technical Evaluation, ETE-NA-2023-0030, Refuel Gate Swap (Unit 2 with Unit 1), on August 18, 2023
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample 1 Partial)
(1)
(Partial)
The inspectors evaluated Unit 2 refueling outage 2R29 outage activities from September 9 to 30, 2023. The inspectors completed inspection procedure Section 03.01, subsections a, b, and c1 through c12.
- (2) The inspectors evaluated Unit 1 forced outage activities associated with the Unit 1 normal letdown control valve repairs in Mode 3 from September 24 to 27, 2023. The inspectors completed inspection procedure Section 03.01, subsections a, b1, b4, b6, and d1.
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (7 Samples)
- (1) Unit 1 'H' emergency diesel generator air compressor planned maintenance under work order (WO) 59203301949, on July 14, 2023
- (2) Unit 1 main generator leads cooling fan belt replacement under WO59203406977, on July 17, 2023
- (3) Unit 1 'B' component cooling water pump planned maintenance under WO59203276962, on July 22, 2023
- (4) Unit 1 'C' main control room chiller pump unplanned maintenance under WO59203407184, on July 23, 2023
- (5) Station blackout diesel generator planned maintenance under WO59203408040, on August 9, 2023
- (6) Unit 1 'A' service water pump motor removal and rewind under WO59203408068, on August 10, 2023
- (7) Unit 2 'A' charging pump planned maintenance under WO59203417736, on August 26, 2023
Surveillance Testing (IP Section 03.01) (3 Samples)
(1)2-PT-82.2A, Emergency Diesel Generator 2H Fast Start, on July 5, 2023
- (2) CY-AA-AUX-310, Diesel Fuel Oil Testing Program, on July 11, 2023 (3)2-PT-66.3, Containment Depressurization Actuation Operational Test, on September 11, 2023
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
(1)2-PT-75.2A.1, Service Water Pump (2-SW-P-1A) Head Curve Verification, on August 18, 2023
Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)
(1)2-PT-61.3, Containment Type C testing (pressurizer sample isolation valve-penetration 56A), on September 13,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Workers exiting the radiologically controlled area (RCA) during Unit 2 refueling outage.
- (2) Workers exiting containment during Unit 2 refueling outage.
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (1) Radiation Work Permit (RWP) 23-2247, reactor coolant pump replacement project
- (3) RWP 23-2256, Unit 2 reactor cavity decontamination activities High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (2 Samples)
The inspectors evaluated licensee controls of the following high radiation areas (HRAs) and very high radiation areas (VHRAs):
- (1) Unit 2 containment RCP motor cubes
- (2) Unit 2 transfer canal Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01)
The inspectors evaluated the licensees performance in controlling, labeling and securing the following radioactive materials:
- (1) Observed and evaluated control, storage, labeling, and securing of radioactive materials in the Protected Area yard and auxiliary building during a refueling outage.
- (2) Observed and evaluated control, storage, labeling, and securing of radioactive materials in warehouse 9 and the receiving warehouse located outside the Protected Area.
- (3) Observed control, storage, labeling, and securing of Category 2 radioactive materials at the steam generator mausoleum located outside the Protected Area.
Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)
The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:
- (1) Unit 1 and 2 radwaste evaporator system (Abandoned In Place)
- (2) AIM/ALPS modular radioactive waste processing system (servicing both units)
Waste Characterization and Classification (IP Section 03.03) (3 Samples)
The inspectors evaluated the following characterization and classification of radioactive waste:
- (1) North Anna Unit 1 Dry Active Waste (DAW) 2022 Sample ID: L98309-2, 10/12/2022
- (2) North Anna Unit 2 DAW - 2022 Sample ID: L95744-1, 04/08/2022
- (3) North Anna Common DAW - 2021 Sample ID: L93000-1, 08/02/2021
Shipment Preparation (IP Section 03.04) (1 Sample)
- (1) Shipment number: 23-1034. The inspectors observed the preparation of radioactive shipment of the Unit 2 A RCP impeller on September 20, 2023. (DOT 7 A Intermodal container with the impeller shipping container inside. UN2915, Yellow III, TI=3.8)
Shipping Records (IP Section 03.05) (4 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
- (1) Shipment Number: 21-BC0-07 - High Integrity Container (HIC) containing bead resin in a shielded transport cask sent to an offsite waste processor. (LSA-II, Exclusive Use)
- (2) Shipment Number: 21-CWF-01 - HIC containing used filters and fill material in a shielded transport cask (LSA-II, Exclusive Use, Category 2 quantity)
- (3) Shipment Number: 22-WCS-01 - HIC containing used filters and bead resin in a shielded transport cask (LSA-II, Exclusive Use)
- (4) Shipment Number: 23-BCO-02 - Two
- (2) sealand containers ESUU300352 and ESUU200648 containing used filters and waste oil sent to an offsite waste processor.
(LSA-II, Exclusive Use)
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, 2022, through June 30, 2023)
- (2) Unit 2 (July 1, 2022, through June 30, 2023)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) March 1, 2022, through August 31, 2023 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) March 1, 2022, through August 31, 2023
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) CR1228449, Fire Truck Battery Depleted, on August 9, 2023
- (2) CR1220506, 0-PT-37.1 Due 10/24/22 Not Included in Review of Partial PTs, on July 10, 2023
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) CRs related to minimum staffing not met for Operations for extended loss of A/C power (ELAP) conditions (CR1221495, CR1218094, CR1216482, CR1216174, CR1214946, CR1213041, CR1216028, CR1215619, CR1215536, CR1212621, CR1212061, CR1211645, CR1225184)
INSPECTION RESULTS
Unresolved Item (Open)
Moisture Intrusion Resulting in Station Blackout (SBO) Radiator Fan Motor Issues URI 05000338,05000339/2023003-01 71111.12
Description:
An unresolved item (URI) was identified related to the licensees identification and correction of moisture intrusion into the B SBO diesel generator radiator fan motor.
On February 5, 2023, approximately an hour into periodic test 0-PT-82.12, "Quarterly Test of 0-AAC-DG-0M, Alternate AC Diesel Generator (SBO Diesel), on the 'E' Transfer Bus," an emergent shutdown of the SBO diesel generator was performed due to indications of high lube oil and jacket coolant water temperatures. The SBO diesel generator was immediately declared nonfunctional and an investigation into the cause was completed. The licensee's troubleshooting found the breaker to the 'B' SBO diesel generator radiator fan tripped. Subsequent evaluation by the licensee and vendor analysis revealed the B motor experienced a moisture-induced failure from water intrusion. Specifically, the evaluation noted "moisture intrusion...caused insulation breakdown in the winding and grounding [on all three phases] of the motor." Results from the vendor analysis also revealed rust throughout the motors interior and significantly degraded internals due to excess water inleakage. The motor was replaced, and the system was restored to service on February 8.
The inspectors reviewed the details of the February event along with the vendor technical manual, motor preventive maintenance history and assignments, station narrative logs, condition reports, and site-specific operating experience associated with the radiator fan motor failure. Based on their review, the inspectors could not identify efforts taken by the licensee to keep the SBO radiator fan motor exteriors free of water, as recommended by the vendor, although both SBO radiator fan motors are located outside and susceptible to water accumulation from humidity/ temperature changes or weather conditions such as rain, sleet, snow, or hail. In addition, the inspectors noted other tasks such as periodic insulation resistance testing, regular draining of the SBO radiator fan motor housings, and periodic lubrication/greasing of the motor bearings were not being performed, as recommended by the vendor. These observations were provided to the licensee.
In response to the inspectors observations, the licensee verified the SBO radiator fan motors were procured with drains. The licensee informed the inspectors the motors had t-slot drains which did not appear to function as designed and therefore it would need to further investigate the reason or cause. Based on this new information, the inspectors reviewed DOM-QA-1 (Dominion Quality Assurance Program Topical Report, Revision 30) and could not conclude a performance deficiency existed. Specifically, Appendix F, Section 1.16, "Corrective Actions," states, "Dominion employs measures to ensure that failures, malfunctions, deficiencies, deviations, defective components, and non-conformances are properly identified, reported, and corrected." A URI is opened pending information from the licensee.
During their inspection, the inspectors also became aware of two events that had the potential to influence disposition of the URI. A 2016 apparent cause evaluation (ACE)documented an event in which the SBO diesel generator experienced high lube oil and jacket water temperatures, tripping of the A SBO radiator fan breaker, and grounding of the A radiator fan motor. Although considered, water intrusion was refuted as a cause. Similarly, a July 2023 condition report documented an event in which the A SBO radiator fan motor bearings were discovered degraded resulting in an emergent shutdown of the SBO diesel generator during testing. The A radiator fan motor was subsequently replaced and discovered with water pouring from the inside. Initial investigation by the licensee determined the cause of the July 2023 A SBO radiator fan motor issues to be the result of water intrusion. No formal causal evaluation was performed by the licensee; however, the motor was shipped offsite for analysis with pending results.
Due to unavailability of information, the inspectors could not determine if either event was related to the February 5, 2023, B SBO radiator fan failure.
Planned Closure Actions: The inspectors will review the licensee's updated evaluation and/or supporting documentation or references associated with the 'B' SBO radiator fan motor failure. The inspectors will also review the vendor analysis for the 'A' SBO radiator fan motor degradation along with supporting documentation or references related to the July 2023 event. The inspectors have requested the documented corrective actions from the 2016 ACE and the 2023 vendor analysis to make a determination of any performance deficiencies.
Licensee Actions: In response to both the 'A' and 'B' SBO radiator fan events, the licensee replaced the radiator fan motors and performed successful tests of the SBO diesel generator on February 8, 2023, and July 25, 2023, respectively. The licensee's interim corrective actions included installation of a cover over the motors to redirect water from entering the motors.
Corrective Action References: CR1218825, CR1234897, CR1234896, CA11455419, CR1233878, CR1233999 Observation: Occasional Lapses in Full Staffing of the Mitigation of Beyond Design Basis Extended Loss of A/C Power Event 71152S The inspectors performed a semi-annual trend review of 53 corrective action documents from June 2022 to July 2023 associated with North Anna's inability to meet minimum staffing requirements for mitigation of an extended loss of A/C power (ELAP) beyond design basis event (BDBE). The inspectors performed this review to determine 1) if a trend existed, 2) that the identified issues were not indicative of a more significant safety concern, and 3) that the identified issues were captured in the licensee's corrective action program and trended.
The importance of ELAP staffing is discussed in the statements of consideration for Title 10 of the Code of Federal Regulations (10 CFR) 50.155, "Mitigation of Beyond Design Basis Events," Federal Register (FR), (Vol. 84, No. 154, Friday, August, 9, 2019 page 39692), as well as Dominion procedure CM-AA-BDB-10, "Beyond Design Basis Flex Program."
Pertaining to 10 CFR 50.155, the Commission noted that staffing was taken into consideration by licensees in developing and implementing their strategies and guidelines.
Additionally, Dominion procedure CM-AA-BDB-10, states, "adequate staffing is an inherent part of the ability to successfully implement MBDBE strategies." The North Anna ELAP staffing requirements are listed in Dominion procedure OP-AA-100, "Conduct of Operations,"
2, Table 5.2-2.
Of the 53 condition reports (CRs), the inspectors noted 7 in which ELAP staffing requirements were unmet for an entire shift (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) due to emergent or unexpected reasons. The inspectors noted these CRs did not address or evaluate whether being below minimum staffing affected the licensee's ability to implement its FLEX strategy. The inspectors qualitatively evaluated the overall impact of being one person below minimum staffing for the ELAP scenario by considering the licensee's required actions when BDBE mitigating strategies are compromised due to equipment unavailability. The inspectors noted that when equipment is unavailable, per CM-AA-BDB-102, "Beyond Design Basis Flex Equipment Unavailability Tracking," 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is typically afforded to recover the equipment and/or make the FLEX strategy available. The inspectors determined the FLEX strategy would take longer to implement with one person below the minimum staffing and thus the impact to the mitigating strategy would be less severe than equipment being unavailable.
While no CRs were found documenting a licensee-identified trend on meeting ELAP staffing requirements, the inspectors acknowledge the licensee's corrective actions to address the ELAP staffing issues. In each instance where staffing was not met, the licensee attempted to occupy the vacancy using processes consistent with the station's bargaining unit agreement and fatigue management requirements, including but not limited to filling the vacancy of the individual with a qualified supervisor. These attempts were unsuccessful 7 of the 53 times.
The licensee currently has ongoing efforts and long-term corrective actions to address occasional staffing lapses through over-hiring in the Operations department and initial training classes for licensed and non-licensed operators and supervisors.
The inspectors ultimately did not determine that the negative trend constituted a more significant safety concern based on their review of licensee actions.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 30, 2023, the inspectors presented the integrated inspection results to Lisa Hilbert, Site Vice President, and other members of the licensee staff.
- On September 21, 2023, the inspectors presented the radiation protection baseline inspection results to Lisa Hilbert, Site Vice President, and other members of the licensee staff.
- On September 21, 2023, the inspectors presented the inservice inspection results to Lisa Hilbert, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
0-FS-CR-1
Control Room - Units 1 & 2 Safe Shutdown Equipment,
1-FS-AB-1
Auxiliary Building (All Elevations) Fire Fighting Strategy Safe
Shutdown Equipment
1-FS-MG-1
Motor Generator Set House Unit 1
Procedures
1-FS-TO-1
Turbine Oil Room Elevation 254' Unit 1 Fire Fighting
Strategy
Corrective Action
Documents
CR1222210
NAPS 1 and 2 5th Interval Period 1 examinations do not
meet code completion percentage
03/22/2023
CR1226002
1-CH-117-VALVE - 2C BA TRANSFER PUMP DISCH 1-CH-
Pl-1105B ISOL VALVE evaluation
05/22/2023
Engineering
Evaluations
CR1226017
1-CH-P-2C-PUMP, 2C Boric Acid Transfer Pump evaluation
05/22/2023
Miscellaneous
Supplemental NDE Personnel Certification Review
Checklists
ISI-2-MT-23-005
PZR Skirt Weld Magnetic Particle Examination
09/15/2023
NDE Reports
ISI-2-UT-23-003
SW-81 Flange to Pipe UT examination
06/21/2023
ER-AA-NDE-MT-
200
Dry Magnetic Particle Examination Procedure Using Yokes
ER-AA-NDE-UT-
801
Ultrasonic Examination of Ferritic Piping Welds in
Accordance with ASME Section XI, Appendix VIII
Procedures
ER-AA-NDE-UT-
2
Ultrasonic Examination of Austenitic Piping Welds in
Accordance with ASME Section XI, Appendix VIII
Work Orders
2-SI-MOV-2869B had excessive leakage during 2-PT-61.4
01/19/2023
Corrective Action
Documents
CR 1204718,
205119,
210963,
218825
Maintenance Rule Functional Failure Evaluations
07/24/2023
CR1232831
07/10/2023
CR1233007
1-HV-MOV-113C, Increased Packing Torque
07/12/2023
Corrective Action
Documents
CR1233022
1-HV-MOV-113C
07/12/2023
CR1233635
07/20/2023
Corrective Action
Documents
CR1233761
07/21/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
23-NFLK-
000TBA
Report of Analysis for diesel fuel oil
07/11/2023
Work Orders
7/18/2023
CA12161432
NRC RP Public Radiation Safety Inspection Comments and
CR1208989 [FME Lanyard Dose Calculation]
09/30/2023
Corrective Action
Documents
CRs 1238032 and
208989
Various
Various
2-OP-4.1
CONTROLLING PROCEDURE FOR REFUELING
Rev. 95
Procedures
Airborne Radioactivity Surveys
Rev. 5
Corrective Action
Documents
Condition Reports: 1189890, and 1221254
Various
Training records for two (2) radioactive material shippers.
09/20/2023
0-PT-153
National Source Tracking System (NSTS) annual verification
of Category 1 and 2 sources - 2022
01/12/2022
0-PT-153
National Source Tracking System (NSTS) annual verification
of Category 1 and 2 sources - 2023
01/09/2023
Document No:
9361854
North Anna Power Station Generation 2 -Type 93A RCP
Shipping Cask Handling Procedure
Revision 001
Miscellaneous
Radioactive
Waste/Material
Qualification List
List personnel authorized to perform independent review of
radioactive material and waste shipment documentation and
approve shipping papers.
08/01/2023
C-HP-1071.040
Packaging and Shipment of Radioactive Material
Revision 20
Procedures
Corrective Action
Revision 41
North Anna Power Station 2022 Annual Radioactive Source
Inventory
01/13/2022
Radiation
Surveys
North Anna Power Station 2023 Annual Radioactive Source
Inventory
01/17/2023
Audit 22-06
Radiological Protection, Process Control Program, and
Chemistry
09/22/2022
PA8332209
Solid Radioactive Waste Control Program Review (October
2019 - October 2021)
10/28/2021
PA9212234
Radioactive Material Control Program Review (11-2019 to
-2022)
09/29/2022
Self-Assessments
PIR1205660
10CFR37.55 Security Program Review
2/15/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Public Cornerstone Condition Reports: 1195129, 1205729,
and 1209613
Various
North Anna 2022 Gaseous Effluents Cumulative Dose
Summary
05/04/2023
North Anna 2022 Effluents Cumulative Dose Summary
05/04/2023
North Anna 2023 Liquid Effluent Release Summary (January
23 through July 2023)
08/08/2023
North Anna 2023 Gaseous Effluent Release Summary
(January 2023 through July 2023)
08/08/2023
Miscellaneous
North Anna Radiation INPO and NRC Radiation Safety
Cornerstone Performance Indicator Data for the period April
22 through July 2023
Various
71151
Procedures
Performance Monitoring
Revision 12
Corrective Action
Documents
CR 1221495,
218094,
216482,
216174,
214946,
213041,
216028,
215619,
215536,
212621,
212061,
211645,
25184
Response to On-Shift Minimum Manning Challenges
07/26/2023
CM-AA-BDB-10
Beyond Design Basis FLEX Program
Procedures
Conduct of Operations
46