IR 05000338/2024010

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NRC Fire Protection Team Inspection (FPTI) Report 05000338/2024010 and 05000339/2024010
ML24144A250
Person / Time
Site: North Anna  
Issue date: 05/24/2024
From: Daniel Bacon
Division of Reactor Safety II
To: Hilbert L
Dominion
References
IR 2024010
Download: ML24144A250 (10)


Text

SUBJECT:

NORTH ANNA POWER STATION - NRC FIRE PROTECTION TEAM INSPECTION (FPTI) REPORT 05000338/2024010 AND 05000339/2024010

Dear Lisa Hilbert:

On May 16, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at North Anna Power Station and discussed the results of this inspection with Mr. James Jenkins, Plant General Manager, 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, Daniel M. Bacon, 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:

NPF-4 and NPF-7

Report Numbers:

05000338/2024010 and 05000339/2024010

Enterprise Identifier:

I-2024-010-0031

Licensee:

Dominion

Facility:

North Anna Power Station

Location:

Mineral, VA

Inspection Dates:

April 29, 2024 to May 16, 2024

Inspectors:

E. Coffman, Reactor Inspector

W. Monk, Senior Reactor Inspector (Team Lead)

A. Ruh, Senior Reactor Inspector (Observing)

D. Strickland, Senior Reactor Inspector

Approved By:

Daniel M. Bacon, Chief

Engineering Branch 2

Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a fire protection team 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 industry 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).

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.

(1) SSC #1 (Fire Prevention) - Transient Combustible Controls Program
(2) SSC #2 (Detection/Suppression) - U1/U2 EDG Heat Detection and Full Area Low Pressure CO2 System
(3) SSC #3 (Safe Shutdown) - U1/U2 EDG System & 4.1KV Emergency Distribution
(4) SSC #4 (Safe Shutdown) - U1/U2 Auxiliary Feedwater (AFW) System

Fire Protection Program Administrative Controls (IP Section 03.02) (2 Samples)

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) Fire Protection Administration Program #1 - Hot Work Program
(2) Fire Protection Administration Program #2 - Fire Brigade Drills and Training 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) FPP Change #1 - App R Report Change Notice N-2021-007-NCR 1172800, 2021 FPTI Discrepancies
(2) FPP Change #2 - App R Report Change Notice N-2022-001 - ETE-NA-2021-0068, EDG Starting Circuit Appendix R Review

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On May 16, 2024, the inspectors presented the Fire Protection Exit Meeting inspection results to Mr. James Jenkins, Plant Manager, and other members of the licensee staff.

THIRD PARTY REVIEWS No third-party reviews were conducted during the inspection period.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

NA-CALC-000-

ME-3031

Seismic/JOG Weak-Link Analysis for FW-MOV-100D

Rev. 1

NA-CALC-000-

ME-3162

JOG Calculation of Required Thrust Settings for MOV-2-

FW-MOV-200D

Rev. 2

NE-0154

Minimum Quantity for Fire Protection Low Pressure CO2

Tanks 1-FP-TK-06 and 1-FP-TK-5

Rev. 2

Calculations

SE-0028

Minimum Levels for the Fire Protection Low Pressure CO2

Tanks

05/25/2021

CA8539011

Evaluate EDG start circuit in accordance with the

requirements of OP-AA-102

07/20/2021

CA8560108

Document the review of the EDG battery negative

conductors in an ETE

08/19/2021

CR 1172800

NRC Identified Discrepancies in the NAPS Appendix R

Report

05/13/2021

CR 1177199

App R concern identified with cable separation associated

with U1&U2 EDG and Emergency Bus Operation

07/20/2021

CR 1177399

Update to CR1177199 App R concern with U1 & U2

EDG/Emerg Bus BKR Cable Separation

07/22/2021

CR 1199293

Inadvertent CO2 Release in 2H EDG Room

05/12/2022

CR 1205683

Crack on 6-ton CO2 Tank Fill Line

08/15/2022

CR 1219577

Operations Minimum Fire Brigade Staffing Not Met per TR

7.3

2/14/2023

CR 1226275

NRC Identified: Transient fire loading report in U1 cable

spreading room Questioned

04/27/2023

CR 1230930

Audit Recommendation as a result of NOD Audit 23-04:

Fire Protection QA Program and Implementation

06/14/2023

CR 1235778

Observed minor CO2 line Corrosion above 2-FP-89

Caused by Overhead Drain Leak

08/17/2023

CR 1246311

NRC Identified a Penetration in the Aux building (244)

that Appeared Degraded

2/14/2023

71111.21N.05

Corrective Action

Documents

CR 1247679

Operations below OP-AA-100 - Conduct of Operations

manning requirements - ELAP only

01/7/2024

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CR 1249239

Control of Combustible and Flammable Material CBT not

assigned IAW with the Training Program Guide

01/24/2024

CR 1250480

1-FP-P-10-ENGINE oil sample 1/23/2024; fuel dilution

(5.9%), viscosity (7.7 cSt)

2/8/2024

CR 1253981

2J EDG Room North Door will not Latch

03/19/2024

CR1177199

App R concern identified with cable separation associated

with U1&U2 EDG and Emergency bus operation

07/20/2021

CR 1258107

NRC Identified 2J EDG Room Non-Appendix R

Emergency Light Lamp not Directed at Pathway

04/30/2024

CR 1258254

NRC Identified Plastic Bottle with Fluid Found in U2 Cable

Vault / Tunnel

05/01/2024

CR 1258259

NRC Identified Transient Combustibles Outside U1

Control Room Door (printer paper)

05/01/2024

CR 1258262

NRC Identified Transient Material in U1 Cable Vault and

Tunnel

05/01/2024

CR 1258290

NRC Identified: Minor Discrepancies Identified in FCA

Procedures

05/02/2024

CR 1258373

NRC Identified: Small Access Door Missing from 02-BLD-

STR-S71-12

05/02/2024

CR 1259519

NRC Identified: Plastic bottle with fluid found in U2 Rod

Drive Room

05/15/2024

CR 1259521

NRC Identified: Plastic bottle with fluid found in U2 Cable

Vault / Tunnel

05/15/2024

Corrective Action

Documents

Resulting from

Inspection

CR 1259525

NRC Identified: FCA steps for establishing AFW do not

contain explicit steps to prevent SG Overfill

05/15/2024

CR 1259641

NRC Fire Protection Team Inspection Exit Meeting

05/16/2024

11715-DAR-74A

Appendix 'R' Safe Shutdown Flow Diagram Feedwater

Rev. 7

11715-DAR-74A

Appendix R SSD Flow Diagram for U1 Feedwater

Rev. 7

11715-ESK-11C

Elementary Diagram Emer Diesel Gen 1H Sh. 1

Rev. 29

11715-FAR-206

Equipment Location - APP R Service Building Plan EL

271 - 6

Rev. 7

Drawings

2050-ESK-11C

Elementary Diagram Emer Diesel Gen 2H Sh. 1

Rev. 28

Engineering

Changes

ETE-NA-2021-

0068

Emergency Diesel Generator Starting Circuit Appendix R

Review

Rev. 0

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

N-2021-007

Change Evaluation to Appendix R Report

10/01/2021

ET CEP 00-0043

Availability of MOV's for Local Operation

Rev. 0

ET-N-09-0063

Appendix R Assumptions for Operator Manual Actions

Rev. 1

ETE-CEP-2011-

0003

Appendix R Multiple Spurious Operation (MSO)

Identification and Evaluation - North Anna Units 1 and 2

Rev. 3

Engineering

Evaluations

NA-ETE-000-

ETE-CEP-2011-

0003

Risk Screening for Previously Identified MSO's

Rev. 3

1-FS-AF-1

SAFE SHUTDOWN EQUIPMENT AUXILIARY

FEEDWATER PUMPHOUSE Unit 1

Rev. 3

1-FS-DR-1

UNIT 1 AND 2 EMERGENCY DIESEL ENGINE ROOMS

Rev. 8

1-FS-S-3

UNIT 1 EMERGENCY SWITCHGEAR INSTRUMENT

RACK AND AIR CONDITIONING ROOMS SERVICE

BUILDING ELEV. 254 FT (S-54) SAFE SHUTDOWN

EQUIPMENT

Rev. 15

Fire Plans

2-FS-AF-1

FIRE FIGHTING STRATEGY FOR SAFE SHUTDOWN

EQUIPMENT FOR AUXILIARY FEEDWATER

PUMPHOUSE

Rev. 2

O-FPMA-3

SCBA Operability Test

05/10/2024

O-FPMA-3

SCBA Operability Test

04/09/2024

SA-AA-115

Fire Drill Evaluation Form

2/03/2023

SA-AA-115

Fire Drill Evaluation Form

2/16/2024

SDBD-NAPS-

AFW

System Design Basis Document for Auxiliary Feedwater

System North Anna Power Station

03/15/2023

Miscellaneous

SDBD-NAPS-EG

System Design Basis Document Emergency Diesel

Generator System

Rev. 36

0-FCA-0

Fire Protection Operations Response

Rev. 22

0-FCA-1

Control Room Fire SSD Procedure

Rev. 57

0-GOP-17.0

Time Critical Action Validation and Verification

Rev. 17

0-PT-107.0

Periodic Appendix R Locker Inspection

04/01/2024

1-FCA-2

Unit 1 ESGR SSD Procedure

Rev. 50

Procedures

1-FCA-3

Cable Vault and Tunnel Fire SSD Procedure

Rev. 39

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

1-FPMP-2.10

Fire Protection Maintenance

Rev. 10

2-FPMP-2.2

Loss Prevention Fire Protection Maintenance

Rev. 14

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. 17

O-FPMP-2.6

Loss Prevention Fire Protection Maintenance

Rev. 4

OP-AA-100

Conduct of Operations

Rev. 47

SA-AA-115

CONDUCT OF FIRE DRILLS

Rev. 8

VPAP-0505

Writers Guide for Dual-Column Procedures

Rev. 9

Self-

Assessments

PIR1152016

NAPS Pre-TFPI 2021 Self-Assessment

7/27/2021