IR 05000338/2023010
| ML23150A252 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/31/2023 |
| From: | Matthew Fannon Division Reactor Projects II |
| To: | Stoddard D Dominion Energy Virginia, Virginia Electric & Power Co (VEPCO) |
| References | |
| IR 2023010 | |
| Download: ML23150A252 (17) | |
Text
SUBJECT:
NORTH ANNA POWER STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000338/2023010 AND 05000339/2023010
Dear Daniel Stoddard:
On May 5, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your North Anna Power Station. On May 4, 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.
The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection.
May 31, 2023 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:
05000338/2023010 and 05000339/2023010
Enterprise Identifier:
I-2023-010-0030
Licensee:
Dominion Energy (Virginia Electric Company)
Facility:
North Anna Power Station
Location:
Mineral, VA
Inspection Dates:
April 17, 2023 to May 5, 2023
Inspectors:
J. Seat, Senior Project Engineer
N. Smalley, Resident Inspector
D. Turpin, Resident Inspector
A. Wilson, Senior Project Engineer (Team Leader)
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 a biennial problem identification and resolution 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
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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.
Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors conducted an in-depth corrective action program review of the following systems or portions thereof: emergency diesel generators, service water, high head safety injection, and control room and emergency switchgear room HVAC. The inspectors also conducted a five-year review of equipment aging issues.
Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.
Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.
Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B 1) Corrective Action Program Effectiveness
Problem Identification: The inspectors determined that the licensee was generally effective in identifying problems and entering them into the corrective action program, and there was a low threshold for entering issues into the corrective action program. This conclusion was based on a review of the requirements for initiating condition reports as described in licensee procedure PI-AA-200, Corrective Action. Additionally, site management was actively involved in the corrective action program and focused appropriate attention on significant plant issues. The inspectors documented one observation regarding a delay in entering conditions adverse to quality into the corrective action program. The observation is discussed in detail in the Inspection Results section of this report. The licensee initiated condition report (CR) 1227223 based on this observation.
Problem Prioritization and Evaluation: Based on the review of condition reports, work orders, and work requests, the inspectors concluded that problems were prioritized and evaluated in accordance with licensee guidance. The inspectors determined that adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that, in general, plant personnel had conducted cause evaluations in compliance with the licensees corrective action program procedures and cause determinations were appropriate, and considered the significance of the issues being evaluated.
Corrective Actions: Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that, generally, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected. The team determined that the licensee was generally effective in developing corrective actions that were appropriately focused. The inspectors noted that while issue evaluations were generally sound, there were several examples where additional research was needed to verify that the appropriate corrective actions were taken, primarily due to a lack of clear documentation.
Based on the samples reviewed, the team determined that the licensees corrective action program complied with regulatory requirements and self-imposed standards. The licensees implementation of the corrective action program adequately supported nuclear safety.
2) Operating Experience
The team determined that the stations processes for the use of industry and NRC operating experience information were effective and complied with regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The team concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented in accordance with applicable procedures.
3) Self-Assessments and Audits
The inspectors determined that the licensee was effective at performing self-assessments and audits to identify issues at a low level, properly evaluated those issues, and resolved them commensurate with their safety significance. The self-assessments and audits were adequately self-critical and performance-related issues were being appropriately identified. The inspectors verified that action requests were created to document areas for improvement and findings and verified that actions generally had been completed consistent with those recommendations.
4) Safety-Conscious Work Environment Employees interviewed appeared willing to raise nuclear safety concerns through at least one of the several means available. Based on interviews with plant staff and reviews of the latest safety culture survey results, the team found no evidence of challenges to a safety conscious work environment.
Observation: Delay In Initiating Condition Reports For Conditions Adverse To Quality 71152B The inspectors observed three examples of delays in entering NRC identified conditions adverse to quality into the corrective action program. During the first week of the inspection, the inspection team identified issues during plant walkdowns that were communicated to licensee staff on April 20. The inspection team questioned a scaffold built in the service water pump house, where the scaffold did not have the semiannual inspection completed in accordance with procedure MA-AA-105, Scaffolding. The inspection team also questioned a catch container that had been hung in the auxiliary service water pump house, where the material should have been documented using a transient loading permit. These two NRC identified issues were known to licensee staff but were not placed into the corrective action program until May 2.
The inspectors also identified transient combustible material in the Unit 1 control room HVAC room. Specifically, a mop, bucket, and chair were identified in this room during an NRC walkdown on April 19. The inspectors questioned if this material should have required a fire transient loading sheet and if it was an appropriate storage location for the combustible material. The combustible material remained in the room through May 1 and a condition report was not entered into the corrective action program until May 4. The response received from licensee staff indicated that this material can be considered routine, permanent, day-to-day materials, which would be exempt from the requirements of CM-AA-FPA-101, Control of Combustible and Flammable Materials. However, the inspectors observed that permanent day-to-day materials are not defined in calculation ETE-NA-2011-021 (Evaluation of Permanently Stored Combustible Material), and the specific materials identified by the NRC were not listed by example in Attachment 1 of ETE-NA-2011-021, which represents the baseline for permanently stored combustible material. Regardless of the classification of the materials, the significance of this observation is minor based on the added mass of about 20 pounds of the items is considered negligible and has no impact to the Equivalent Fire Severity (EFS) of the area.
The inspectors noted that since these issues were not entered into the corrective action program until 12 - 15 days after the identification of the issue, there may have been a missed opportunity to receive a timely review by station management and operations staff, particularly to be screened for operability or potential impact on the plant. In this case, following review of the CRs by the station it was determined that there was no safety impact for the three issues identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On May 4, 2023, the inspectors presented the biennial problem identification and resolution 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
Combustible Loading Analysis North Anna Power Station,
Units 1 and 2
Rev. 22
ETE-CCE-2022-
0001
Implementation of Spent Fuel Cask Orientation Controls that
Conform to Original Licensing Basis
Rev. 0
Calculations
ETE-NA-2011-
21
Evaluation of Permanently Stored Combustible Material
Rev. 9
Corrective Action
Documents
CA11083924,
CA11108563,
CA11113092,
CA11214300,
CA11221094,
CA11221094,
CA11246090,
CA11328250,
CA11348778,
CA11431126,
CA1173379,
CA7612615,
CA8114916,
CA8457089,
CA8539011,
CA8543311,
CA8587871,
CA8591611,
CA8608563,
CA9178937,
CR1043540,
CR1055192,
CR1062889,
CR1097220,
CR1125435,
CR1126356,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR1136138,
CR1136938,
CR1138336,
CR1144530,
CR1149974,
CR1158147,
CR1162008,
CR1162240,
CR1166315,
CR1169253,
CR1169816,
CR1169889,
CR1169991,
CR1171277,
CR1171926,
CR1172237,
CR1173212,
CR1173394,
CR1173507,
CR1173825,
CR1174192,
CR1174622,
CR1174823,
CR1175205,
CR1175836,
CR1176116,
CR1176214,
CR1176575,
CR1176804,
CR1177032,
CR1177199,
CR1177249,
CR1177773,
CR1177824,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR1178210,
CR1178801,
CR1178906,
CR1179130,
CR1179442,
CR1179746,
CR1181190,
CR1181355,
CR1181542,
CR1182013,
CR1182197,
CR1182226
CR1182755,
CR1182825,
CR1183419,
CR1183893,
CR1184295,
CR1184427,
CR1184816,
CR1185017,
CR1187508,
CR1187510,
CR1188701,
CR1189232,
CR1189390,
CR1191508,
CR1193192,
CR1193959,
CR1194892,
CR1195347,
CR1195511,
CR1198094,
CR1198530,
CR1198941,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR1199000,
CR1199293,
CR1199453,
CR1200985,
CR1201209,
CR1201215,
CR1201299,
CR1201308,
CR1201515,
CR1201901,
CR1202614,
CR1203090,
CR1203216,
CR1203804,
CR1203956,
CR1204718,
CR1204953,
CR1205215,
CR1205378,
CR1205485,
CR1205695,
CR1205741,
CR1206541,
CR1207076,
CR1207336,
CR1208331,
CR1208534,
CR1209396,
CR1209567,
CR1209626,
CR1210037,
CR1210274,
CR1210277,
CR1210660,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR1211117,
CR1212304,
CR1213394,
CR1213473,
CR1213487,
CR1213830,
CR1214487,
CR1214742,
CR1214932,
CR1214938,
CR1215118,
CR1215319,
CR1216422,
CR1216605,
CR1216926,
CR1217001,
CR1217212,
CR1217421,
CR1217512,
CR1217588,
CR1217714,
CR1217751,
CR1218441,
CR1218825,
CR1219118,
CR1219832,
CR1219875,
CR1221182,
CR1221343,
CR1223140
CR1225269
Dry Boric Acid Observed in the Packing Area of 1-CH-MOV-
289A - NRC identified
Corrective Action
Documents
Resulting from
Inspection
CR1225270
Dry Boric Acid Observed in the Packing Area of 1-CH-MOV-
289B - NRC identified
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR1225274
Dry Boric Acid Observed in the Packing Area of 2-CH-MOV-
289A - NRC identified
CR1225277
Dry Boric Acid Observed in the Packing Area of 1-SI-MOV-
1864B - NRC identified
CR1225278
Dry Boric Acid Observed in the Packing Area of 2-CH-MOV-
289B - NRC identified
CR1225279
Dry Boric Acid Observed in the Packing Area of 1-SI-MOV-
1867B - NRC identified
CR1225282
Purpose of Copper Wire attached to 2-CH-MOV-2289B
Questioned - NRC Identified
CR1225283
Dry Boric Acid Observed in the Packing Area and on one
stud and nut of 2-CH-FCV-2122 - NRC identified
CR1225284
Unlatched Clip Observed on Insulation for 1-CH-FL-1
CR1225286
Dry Boric Acid Observed in the Packing Area of 1-CH-FCV-
1113A - NRC identified
CR1225288
Dry Boric Acid Observed in the Packing Area of 1-CH-FCV-
22 - NRC identified
CR1225289
Dry Boric Acid Observed in the Packing Area of 2-CH-FCV-
2113A - NRC identified
CR1225291
Dry Boric Acid Observed in the Packing Area of 1-CH--288 -
NRC identified
CR1226877
Hand rail not inspected - NRC identified
CR1226912
Transient Fire Loading sheet not used in ASWPH - NRC
identified
CR1227223
23 NRC PI&R Exit Meeting Observation
CR1227226
23 NRC PI&R Exit Meeting Comments
CR1227227
23 NRC PI&R Exit Meeting Minor Violation
CR1227231
NRC Identified Transient Combustibles in Unit 1 HVAC
Room on 4/19/2023
Unit 1 Cycle 29 Refueling Outage Safety Plan Review
08/11/2022
1R29 Risk Charter
Miscellaneous
SBDB-NAPS-HC
System Design Basis Document for Control Room
Ventilation System
Rev. 25
Procedures
0-ICM-SEC-MIS-
Instrument Corrective Maintenance
Rev. 6
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
001
0-MCM-1110-01
Removal of Reactor Vessel Head
Rev. 51
0-OP-5.50
NUHOMS EOS 37 PTH Dry Shielded Canister Loading and
Handling
Rev. 4
1-OP-4.1
Controlling Procedure for Refueling
Rev. 96
CM-AA-FPA-100
Fire Protection / Appendix R (Fire Safe Shutdown) Program
Rev. 20
CM-AA-FPA-101
Control of Combustible and Flammable Materials,
Rev. 15
Identifying and Addressing Nuclear Safety and Quality
Concerns
Rev. 1
Preventive Maintenance Program
Rev. 16
ER-AA-MRL-100
Implementing Maintenance Rule
Rev. 15
ER-AA-SYS-1001
System Health Report
Rev. 13
ER-AP-BAC-101
Boric Acid Corrosion Control Program Inspections
Rev. 16
NF-AA-PRA-370
Probabilistic Risk Assessment Procedures and Methods:
MRule (a)(4) Risk Monitor Guidance
Rev. 22
Conduct of Operations
Rev. 46
Rev. 17
Self Evaluation and Trending
Rev. 26
Self-Assessments
Rev. 14
Operating Experience Program
Rev. 19
Corrective Action
Rev. 40
Cause Evaluation
Rev. 18
Root Cause Evaluation
Rev. 14
Cause Evaluation Methods
Rev. 7
Level of Effort Evaluation
Rev. 2
VPAP-0809
NUREG-0612 Heavy Load Program
Rev. 11
Work Management
Rev. 37
Maintenance Rule (a)(3) Periodic Assessment for the period
of 3/1/2020 to 9/1/2021
Q4-2022 Safety Injection System Health Report
04/03/2023
Audit 21-05
Corrective Action, Independent Review, and License
Conditions
Self-Assessments
Audit 21-06
Nuclear Training
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Audit 21-08
NAPS Fire Protection QA Program and Implementation
Audit 21-11
Offsite Dose Calculation Manual, Radiological Environmental
Monitoring Program, Environmental Protection Plan, & SPS
Refueling
Audit 22-01
Cyber Security, Fitness For Duty, and Unescorted Access
Authorization
Audit 22-02
Audit 22-06
Radiological Protection, Process Control Program, and
Chemistry
Audit 22-07
Operations
Audit 22-09
Maintenance
PIR1163886
Self Assessment on Operator Fundamentals
PIR1164272
21 Pre-PI&R Assessment
PIR1173243
IN 21-01, Lessons Learned from U.S. Nuclear Regulatory
Commission Inspections of Design-Basis Capab
PIR1178557
21 Teams DBAI Self-Assessment (NAPS)
PIR1179188
IN21-03, Operating Experience Related to the Duane Arnold
Energy Center Derecho Event on August 10, 2021
PIR1179189
IN21-02, Recent Issues Associated with Monitoring
Occupational Exposure to Radiation from Licensed
PIR1182118
21 Mid-Cycle Report
PIR1185894
21 EDG Self Assessment
PIR1185894
Perform a SA on the station EDG. Focus on improving
existing processes
PIR1191629
Part 21 2021-28-00 Callaway
PIR1199649
22 Pre-NRC Exercise Inspection
PIR1200431
23 Pre-PI&R Assessment
PIR1204788
Radiation Protection Program Review
PIR1217898
RP Department Self-Assessment on Communication and
Implementation of Operating Experience
PIR1220138
Part 21 2022-26-01 - Flowserve-Limitorque - Interim Report
Notification Regarding Peerles
Work Orders
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date