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– Quadrennial Focused Engineering Inspection Commercial Grade Dedication Report 05000338/2023011 and 05000339/2023011
	ML23267A001
Person / Time
Site:	North Anna
Issue date:	09/26/2023
From:	James Baptist; Division of Reactor Safety II
To:	Carr E; Dominion Nuclear
References
	IR 2023011
	Download: ML23267A001 (1)
	v • d • e

SUBJECT:

NORTH ANNA POWER STATION, UNITS 1 & 2 - QUADRENNIAL FOCUSED ENGINEERING INSPECTION (FEI) COMMERCIAL GRADE DEDICATION REPORT 05000338/2023011 AND 05000339/2023011

Dear Eric S. Carr:

On August 17, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at North Anna Power Station, Units 1 & 2 and discussed the results of this inspection with Mr.

Jim Jenkins, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at North Anna Power Station, Units 1 & 2.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at North Anna Power Station, Units 1 & 2.

September 26, 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, James B. Baptist, Chief Engineering Branch 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:

05000338/2023011 and 05000339/2023011

Enterprise Identifier:

I-2023-011-0029

Licensee:

Dominion Nuclear Company

Facility:

North Anna Power Station, Units 1 & 2

Location:

Mineral, VA

Inspection Dates:

July 24, 2023, to August 11, 2023

Inspectors:

P. Braxton, Reactor Inspector

S. Campbell, Senior Reactor Systems Engineer

R. Fanner, Reactor Inspector

Approved By:

James B. Baptist, Chief

Engineering Branch 1, Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Quadrennial Focused Engineering Inspection (FEI) Commercial Grade Dedication at North Anna Power Station, Units 1 & 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

Corrective actions to verify material characteristics of item procured not consistent with procurement technical evaluation (PTE)

Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000338,05000339/2023011-01 Open/Closed

[P.3] -

Resolution 71111.21N.

The

NRC-Identified

a Green finding associated with a Non-cited violation of Title 10 CFR Part 50 Appendix B Criterion XVI, Corrective Action, for failure to verify material characteristics of an item procured were consistent with the procurement technical evaluation (PTE).

Specifically, the material properties were not verified consistent with the PTE methodology which directed verification of material characteristics to mitigate previous deficiencies in accordance with the instructions contained in MS-AA-MVL-101, Receipt Inspection, Rev 9 and the criteria added in PTE 10000012272, Rev. 11.

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.

REACTOR SAFETY

71111.21N.03 - Commercial Grade Dedication Commercial Grade Dedication (section 03.01)

Main article: IP 71111.21

(1) SCR, 42291078

(2) Transmitter, 42488999

(3) Belts, 37094110

(4) Valve, 42019703

(5) Bearings, 42091523

(6) Oil 42137857

(7) Oil, 37696340

(8) Circuit Breaker 480 V, 16455490

(9) Time delay relay, 03421330

(10) Control Relay 125 V DC, 06130460

(11) Printed Circuit Board, Amplifier,

INSPECTION RESULTS

Corrective actions to verify material characteristics of item procured not consistent with procurement technical evaluation (PTE)

Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000338,05000339/2023011-01 Open/Closed

[P.3] -

Resolution 71111.21N.0 The NRC-Identified a Green finding associated with a Non-cited violation of Title 10 CFR Part 50 Appendix B Criterion XVI, Corrective Action, for failure to verify material characteristics of an item procured were consistent with the PTE. Specifically, the material properties were not verified consistent with the PTE methodology which directed verification of material characteristics to mitigate previously deficiencies in accordance with the instructions contained in MS-AA-MVL-101, Receipt Inspection, Rev 9 and the criteria added in PTE 10000012272, Rev. 11.

Description:

The team identified an issue of concern related to the failure to adequately use the Fourier Transform Infrared Report (FTIR) test methodology (Method 1) to support the destructive testing criteria to verify the critical characteristics of Material ID, 37094110. FTIR is a common form of infrared spectroscopy. This methodology was based on review of corrective actions from condition report, SU-CR-000-CR1208021. This report identified a failure of similar belts at the Surry facility on or around September 18, 2022, where belts failed on multiple instances. In review of the condition report, one of the contributing causes for the failures were related to vendor quality issues. As a result, in support of Material ID 37094110, North Anna modified the acceptance criteria for the destructive testing of belts to utilize the FTIR methodology. Specifically, in PTE 10000012272, Rev. 11, the licensee specified the performance of FTIR testing to validate that belts were comprised of Ethylene Propylene Diene Terpolymer (EPDM) rubber, the inner cords were made of polyester, and the outer fabric sleeve was made of polyester fabric. Based on information reviewed, the licensee appeared to have missed this attribute and accepted the belts into stock. Based on the review of UD Lot Results With Parts Used WO Data - 6-13-2023, UD Data tab, two different belts associated with the PTE were received on April 17, 2023, for Material ID 37094110 and April 13, 2023, for Material ID 37094130.

The team concluded the procurements received specifying the FTIR methodology were also necessary since two commercial vendors were used to procure belts under this PTE based on Material ID 37094130. This material ID was not a part of the original inspection scope but revealed itself based on the use of PTE 10000012272, Rev. 11, which linked both material IDs. In addition, the linked material section of the PTE specified these material IDs and had an active status as of March 20,2023. The inspectors also reviewed SU-CR-000-CR1208021, written to address the Surry belt failures, and located the same material IDs referenced in PTE 10000012272, Rev. 11. This supported the basis for concluding the corrective actions were not adequate for the circumstances.

Corrective Actions: The licensee entered the issue into the corrective action program based on CR1235239 & CR1235267 and performed an operability determination.

Corrective Action References: CR-000-CR1208021 was initiated based on the Surry belt failures in 09/18/2022.

Performance Assessment:

Performance Deficiency: The licensee failed to adequately implement corrective actions to ensure the established requirements in MS-AA-MVL-101, Receipt Inspection, Rev 9 were implemented commensurate with circumstances for the performance and documentation of quality receipt inspection activities, to include Material Verification (MV) inspection activities.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the use of the FTIR methodology to verify material characteristics was listed in the PTE for 9 material IDs at North Anna and Surry. Absent NRCs intervention, the licenses failure to establish and perform appropriate acceptance testing for the specified material IDs used for replacements could lead to in-service component deterioration and resultant failures.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. the team determined the deficiency affected the design or qualification of a mitigating SSC, which at the time of the inspection, maintained its operability or PRA functionality. (Screened against IMC 0609, Appendix A, Exhibit 2, Step A1a, Green.) The applicable belts were installed on safety related HVAC systems which were linked to High-risk components, Emergency Switchgear Rooms.

Cross-Cutting Aspect: P.3 - Resolution: The team assessed the issue for cross-cutting aspects and determined one existed using the criteria in IMC 0310, Aspects Within the Cross-cutting Areas. Specifically, the team determined the Problem Identification and Resolution Area, Resolution attribute was most appropriate because the organization did not take effective corrective actions to address issues commensurate with their safety significance (PI.3).

Enforcement:

Violation: Title 10 CFR Part 50 Appendix B Criterion XVI, Corrective Action states, measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material, and equipment, and non-conformances are promptly identified and corrected.

CR-000-CR1208021 was initiated to document the V-belt failures which was adverse to quality. PI-AA-200, Corrective Action was used, in part, to establish measures to be taken to assure that conditions adverse to quality are promptly identified and corrected. PTE 10000012272, Rev. 11 was updated based on the PI-AA-200 procedure and specified the requirements for destructive testing based on corrective actions listed from CR-000-CR1208021.

Section 1, Purpose of MS-AA-MVL-101, Receipt Inspection, Rev 9 requires the specific instruction for ensuring material verification (MV) inspection activities were conducted.

Contrary to the above, the licensee did not accomplish the activity adequately to support correcting the condition documented above by not implementing the instructions contained in MS-AA-MVL-101, Receipt Inspection, Rev 9 and the criteria added in PTE 10000012272, Rev. 11 to support material verification using FTIR. Specifically, the material properties were not verified consistent with the PTE methodology which directed verification of material characteristics to mitigate previously deficiencies within the Dominion Energy fleet.

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 August 17, 2023, the inspectors presented the Quadrennial Focused Engineering Inspection (FEI) Commercial Grade Dedication results to Mr. Jim Jenkins, Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

v t e Inspection Report - North Anna - 2023011
80 \| 81 \| 82 \| 83 \| 84 \| 85 \| 86 \| 87 \| 88 \| 89 \| 90 \| 91 \| 92 \| 93 \| 94 \| 95 \| 96 \| 97 \| 98 \| 99 00 \| 01 \| 02 \| 03 \| 04 \| 05 \| 06 \| 07 \| 08 \| 09 \| 10 \| 11 \| 12 \| 13 \| 14 \| 15 \| 16 \| 17 \| 18 \| 19 \| 20 \| 21 \| 22 \| 23 \| 24 \| 25 \|
2023 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 10(0) 11(0) Security 401(0) 403(0) 402(0) Operator Exams Emergency Planning Other

IR 05000338/2023011