IR 05000338/2025011
| ML25211A243 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 08/04/2025 |
| From: | Shawn Smith NRC/RGN-II/DORS/PB4 |
| To: | Carr E Dominion Energy |
| References | |
| IR 2025011 | |
| Download: ML25211A243 (1) | |
Text
SUBJECT:
NORTH ANNA POWER STATION, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000338/2025011 AND 05000339/2025011
Dear Eric S. Carr:
On June 18, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your North Anna Power Station, Units 1 and 2 and discussed the results of this inspection with Matthew Torres, North Anna Plant Manager, 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 to confirm that the station was complying with NRC regulations and licensee standards. Based on the samples reviewed, the team determined that your program complies with NRC regulations and applicable industry standards such that the Reactor Oversight Process can continue to be implemented.
The team also evaluated the stations effectiveness in identifying, prioritizing, evaluating, and correcting problems, reviewed licensee audits and self-assessments, and its use of industry and NRC operating experience information. The results of these evaluations are in the enclosure.
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.
Two findings of very low safety significance (Green) are documented in this report. These findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
August 1, 2025
If you contest the violations or their significance as 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 and 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 and 2.
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, Steven P. Smith, Chief Reactor Projects Branch #6 Division of Operating 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:
05000338/2025011 and 05000339/2025011
Enterprise Identifier:
I-2025-011-0017
Licensee:
Dominion Energy
Facility:
North Anna Power Station, Units 1 and 2
Location:
Mineral, Virginia
Inspection Dates:
April 28, 2025 to June 18, 2025
Inspectors:
W. Deschaine, Senior Project Engineer
K. Dials, Resident Inspector
A. Knotts, Resident Inspector
D. Turpin, Resident Inspector
R. Wehrmann, Resident Inspector
Approved By:
Steven P. Smith, Chief
Reactor Projects Branch #6
Division of Operating Reactor Safety
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, 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
Failure to Meet Minimum Emergency Plan Staffing Requirements Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000338,05000339/2025011-01 Open/Closed EAF-RII-2025-0147
[H.1] -
Resources 71152B Inspectors identified a green finding and associated non-cited violation (NCV) of 10 CFR 50.54(q)(2)(i) and 10 CFR 50.47(b)(2) due to the licensee's failure to maintain the minimum Emergency Plan (E-Plan) shift staffing as defined in the licensee's Emergency Plan.
Failure to Meet Minimum Flex Staffing Requirements Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000338,05000339/2025011-03 Open/Closed
[P.2] -
Evaluation 71152B Inspectors identified a green finding and associated NCV of 10 CFR 50.155(b)(1) due to the licensee's failure to maintain the minimum shift staffing as defined in OP-AA-100, "Conduct of Operations", which resulted in staffing below the minimum for the licensee's beyond design bases mitigation strategy.
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 also conducted an in-depth corrective action program review of the following systems or portions thereof: main control room and emergency switchgear room HVACs, station black out diesel generator, low head safety injection, seal injection system, and the vital board DC power system. The corrective actions for the following findings and non-cited violations were evaluated as part of the assessment: 2024001-01, 2024001-02, 2024401-01, 2023011-01, 2023-403, 2023-403, 2023-403.
- 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 North Anna Biennial PI&R Assessment 1) Corrective Action Program Effectiveness Problem Identification: The inspectors determined that the licensee was effective in identifying problems and entering them into the corrective action program (which included the work management system), 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.
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 found that issue evaluations were generally sound.
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 Based on both formal and informal interviews conducted with licensee personnel across several organizations and reviews of the latest safety culture assessment results, the team determined that employees felt free to raise issues without fear of retaliation. Those interviewed were knowledgeable of the different avenues available to raise safety concerns, including through us of the Employee Concerns Program and were familiar with who to contact on site. The team found no evidence of challenges to a safety conscious work environment.
Failure to Meet Minimum Emergency Plan Staffing Requirements Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000338,05000339/2025011-01 Open/Closed EAF-RII-2025-0147
[H.1] -
Resources 71152B Inspectors identified a green finding and associated non-cited violation (NCV) of 10 CFR 50.54(q)(2)(i) and 10 CFR 50.47(b)(2) due to the licensee's failure to maintain the minimum Emergency Plan (E-Plan) shift staffing as defined in the licensee's Emergency Plan.
Description:
During the biennial problem identification and resolution inspection, inspectors identified condition reports (CRs) that document licensee E-Plan staffing falling below minimum on-shift requirements as specified in the E-Plan. The reduced staffing degraded the station E-Plan as evidenced by six CRs written on April 22, 2024, July 22, 2024, September 06, 2024, September 25, 2024, October 30, 2024, and November 01, 2024.
North Anna Power Station (NAPS) Emergency Plan Section 5.2.1.2, "Emergency Communicators," states, in part, that: "The Emergency Communicators report to the SEM in the Control Room prior to activation of the TSC and CERC. The primary duties of the emergency communicators are to initially notify and periodically update the Emergency Operations Centers of the counties within the 10-mile Emergency Planning Zone, the Virginia Emergency Operations Center (VEOC), and the NRC."
Table 5.1, Minimum Staffing Requirements for Emergencies of the NAPS E-Plan specifies that two emergency communicators are required to notify offsite support groups and maintain communications.
Section 6.1 Activation of the Emergency Plan states, in part, that: "Dedicated communicators will be available to provide regular updates to state and local officials approximately every 60 minutes, when conditions change or as otherwise agreed, and to maintain a continuous channel of communications with the NRC."
On-site staffing levels below the required minimum could have directly led to challenges in implementation of the stations E-Plan. Additionally, the staffing processes utilized at NAPS did not prevent on-shift staffing levels from falling below the minimum values specified in the stations E-Plan. Specifically, there were six instances where only one of the two dedicated on-shift E-Plan communicators were present.
Corrective Actions: The inspector's observations were documented in the corrective action program and the licensee performed evaluations of the identified conditions. The licensee developed an operations site-specific instruction, assessment tool for watch bill impacts on required roles.
Corrective Action References: CR 1291217, CR 1291220
Performance Assessment:
Performance Deficiency: Failure to maintain minimum on-shift E-Plan staffing was a performance deficiency within the licensees ability to foresee and prevent. Specifically, since April 22, 2024, on two instances the on-shift staffing only had one of the required two emergency plan communicators, and on four other instances the on-shift staffing roles were ambiguously defined where additional in-plant duties potentially could have been assigned to the NRC communicator role that were not prescribed in procedures that could have prevented the individual from performing their E-Plan role as NRC communicator.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the emergency response organization's (ERO) Readiness attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency.
Specifically, the failure to meet the minimum on shift staffing directly challenged the EROs readiness due to not having the minimum staffing that are analyzed to meet the implementation of the emergency plan.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix B, Emergency Preparedness SDP. Using IMC 06 this issue affects the Emergency Preparedness cornerstone since it is a failure to comply with a planning standard. Per table 3 the inspector is directed to IMC 0609 Appendix B. This performance deficiency affects planning standard 10 CFR 50.47(b)(2) and is a failure to comply, not a failure to implement, so the inspector is directed to section 5.2, 10 CFR 50.47(b)(2), Onsite Emergency Organization. Using Table 5.2-1 - Significance Examples §50.47(b)(2) the performance deficiency most closely matches an example of a loss of planning standard function therefore was initially characterized as significance to be determined (TBD).
On July 16, 2025, a significance and enforcement review panel (SERP) was conducted.
Consistent with IMC-0609, Appendix B, Section 5.0.3, the SERP considered the examples in Table 5.2-1 along with the extenuating circumstances and mitigating factors of the case to inform the significance of the finding. The SERP determined that the findings significance is better characterized as Green because it is unreasonable to conclude that the licensees ability to communicate from the control room, prior to other emergency response facilities becoming activated and assuming communication responsibility, would have been significantly impacted to the extent that the communication function would be completely unavailable during an actual emergency.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.
Specifically, OP-AA-100 "Conduct of Operations" did not have sufficient detail to ensure that the shift manager could accurately determine the impact of missing staff on the position and qualification requirements necessary to meet the emergency plan and beyond design basis mitigation strategies.
Enforcement:
Violation: 10 CFR 50.54(q)(2)(i) states, in part, that, a holder of a nuclear power reactor license under this part shall follow and maintain the effectiveness of an emergency plan that meets the planning standards of § 50.47(b).
Planning standard 10 CFR 50.47(b)(2) requires, in part, that, the emergency response plans for nuclear power reactors must meet the following standard: On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available, and the interfaces among various onsite response activities and offsite support and response activities are specified.
Contrary to the above, from April 22, 2024 to November 1, 2024, the licensee failed to follow and maintain an effective emergency plan that met the planning standard in 10 CFR 50.47(b)(2) in that the licensee failed to unambiguously define emergency response responsibilities and maintain adequate staffing to provide initial facility accident response in key functional areas at all times.
Specifically, the licensee failed to clearly define emergency response responsibilities for the NRC communicator position on four occasions and failed to maintain two on-shift communicators on two occasions in accordance with the facilitys emergency plan.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Meet Minimum Flex Staffing Requirements Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000338,05000339/2025011-03 Open/Closed
[P.2] -
Evaluation 71152B Inspectors identified a green finding and associated NCV of 10 CFR 50.155(b)(1) due to the licensee's failure to maintain the minimum shift staffing as defined in OP-AA-100, "Conduct of Operations", which resulted in staffing below the minimum for the licensee's beyond design bases mitigation strategy.
Description:
During a review of corrective action documentation for the biennial problem identification and resolution inspection, inspectors identified 48 instances where the condition reports documented that the licensee was not able to meet the minimum staffing for a period of greater than two hours per OP-AA-100, "Conduct of Operations." These 48 examples were identified over the period of May 5, 2023, through May 31, 2025.
10 CFR 50.155(b)(1) requires, in part, that: "Each applicant or licensee shall develop, implement, and maintain: Mitigation strategies for beyond-design-basis external events Strategies and guidelines to mitigate beyond-design-basis external events from natural phenomena that are developed assuming a loss of all ac power concurrent with either a loss of normal access to the ultimate heat sink or, for passive reactor designs, a loss of normal access to the normal heat sink."
North Anna Power Station (NAPS) Units 1 and 2, NEI 12-01, Phase 2 Extended Loss of Alternating Current Power (ELAP) Emergency Response Organization Staffing Analysis Report, TABLE 2 - Plant Operations & Safe Shutdown Extended Loss of All Power (ELAP)
Minimum Crew (Two Units - Single Control Room) states, in part, that:
a.
Auxiliary Operator #1 Step 2 qualification b.
Auxiliary Operator #2 Step 7 qualification c.
Auxiliary Operator #3 Step 5 qualification d.
Auxiliary Operator #4 Step 5 qualification e.
Auxiliary Operator #5 Step 5 qualification f.
Auxiliary Operator #6 Step 5 qualification g.
Auxiliary Operator #7 Step 5 qualification or Task Qualified h.
Auxiliary Operator #8 Step 5 qualification or Task Qualified OP-AA-100 "Conduct of Operations" Attachment 2 "Shift Operations" Table 5.2-2 North Anna Staffing Requirements states, in part, that: for Position Auxiliary Operator the minimum required staffing is 9 supplemented by notes e and g, which state: note e. Total includes Communicators and Fire Brigade. and note g. To meet requirements of Control Room Fire (0-FCA-1), Extended Loss of Alternating Power (ELAP), Technical Specifications, Emergency Plan, and Federal Energy Regulatory Commission requirements, the following are the minimum qualifications required for an Operations Shift on duty:
- Four Safeguards qualified operators
- One Auxiliary Building qualified operator (State and Local Communicator qualified)
- One Turbine Building qualified operator
- Two Outsides qualified operators
- One Spillway qualified operator" Based on the inspector's questions, the licensee performed an evaluation to determine the impact of the gap in site staffing levels on the implementation of the ELAP mitigation strategy.
The licensee concluded that there were 48 instances where the individuals conducting ELAP actions would have to have additional responsibilities added to be able to implement the beyond design bases mitigation strategy.
The repetitive nature of the site staffing dropping below minimum levels directly led to challenges to implementation of the site beyond design bases mitigation strategies.
Additionally, the staffing processes utilized at NAPS, lacked sufficient detail and rigor to ensure that staffing levels did not drop below the minimum values. Specifically, the processes specified in OP-AA-100 did not ensure that the minimum on-shift staffing met the beyond design bases mitigation strategy at all times.
Corrective Actions: The inspector's observations were documented in the corrective action program and the licensee is performing evaluations of the identified conditions.
Corrective Action References: CR 1291217, CR 1291220
Performance Assessment:
Performance Deficiency: Failure to maintain minimum staffing levels per OP-AA-100 was a performance deficiency within the licensees ability to foresee and prevent. Specifically, the processes for on-shift staffing allowed 48 shifts to go below the minimum shift staffing during the period of May 3, 2023, through May 31, 2025.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to meet the minimum on shift staffing directly challenged the beyond design basis mitigation strategy readiness due to not having the minimum staffing that are analyzed to meet the implementation of the extended loss of all power mitigation strategy.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using IMC 06 this issue affects the mitigating systems cornerstone since it is a failure to comply with flexible coping strategies (FLEX). Per table 2 the inspector is directed to IMC 0609 Appendix A. This performance deficiency affects the 10 CFR 50.155 (b)(1) phase 1 FLEX implementation strategy, using Exhibit 2 - Mitigating Systems Screening Questions Section E. Flexible Coping Strategies questions one and two are answered no which screens the issue to Green.
Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, OP-AA-100 "Conduct of Operations" did not have sufficient detail to ensure that the shift manager could accurately determine the impact of missing staff on the positions and qualification requirements necessary to meet the site's beyond design basis mitigation strategies.
Enforcement:
Violation: 10 CFR 50.155(b)(1) requires, in part, that: "Each applicant or licensee shall develop, implement, and maintain: Mitigation strategies for beyond-design-basis external eventsStrategies and guidelines to mitigate beyond-design-basis external events from natural phenomena that are developed assuming a loss of all ac power concurrent with either a loss of normal access to the ultimate heat sink or, for passive reactor designs, a loss of normal access to the normal heat sink."
Contrary to the above, from May 5, 2023, through May 25, 2025, the licensee failed to maintain the minimum shift complement as defined in the licensee's beyond design basis mitigation strategy. Specifically, there were 48 instances where on-shift staffing levels were below the minimum determined necessary to implement the beyond design basis mitigation strategies.
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 that no proprietary information was retained or documented in this report.
- On June 18, 2025, the inspectors presented the biennial problem identification and resolution inspection results to Matthew Torres, North Anna Plant Manager, and other members of the licensee staff.
- On May 22, 2025, the inspectors presented the initial biennial problem identification and resolution inspection results to Matthew Torres, North Anna Plant Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
242649,
237552,
285945,
280676,
275102,
255286,
284286,
242936,
248052,
275120,
276786,
242853,
255658,
29133,
233396,
233990,
240502,
241006,
242383,
243806,
246026,
204671
CR 1290606
NRC Identified - Boric Acid Residue Observed on
Components in Unit 1 Safeguards
05/01/2025
CR 1290609
NRC Identified - Boric Acid Residue Observed on
Components in U1 Aux Bldg Area
05/01/2025
CR 1291217
Organizational and Department specific actions not
adequately documented in CAP
05/07/2025
Corrective Action
Documents
Resulting from
Inspection
CR 1291220
Analyze and Determine Impact on E-Plan due to Ops
Staffing Levels
05/07/2025
DOM-QA-1
Nuclear Facility Quality Assurance Program Description
Procedures
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PI-AA-200
Cause Evaluation
Cause Evaluation Methods
Level of Effort Evaluation
Audit 23-05
Corrective Action, Independent Review, and Licensing
Conditions
08/09/2023
Audit 24-02
04/10/2024
Self-Assessments
PIR1220682
NAPS Emergency Preparedness (EP)
Work Orders
203457808
203418055
203418199
203403889
203406832
203418055
Various
Various