IR 05000338/2017009
| ML17227A373 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 08/15/2017 |
| From: | Reinaldo Rodriguez Reactor Projects Branch 7 |
| To: | Stoddard D Virginia Electric & Power Co (VEPCO) |
| References | |
| IR 2017009 | |
| Download: ML17227A373 (14) | |
Text
UNITED STATES ust 15, 2017
SUBJECT:
NORTH ANNA POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000338/2017009 AND 05000339/2017009
Dear Mr. Stoddard:
On July 27, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your North Anna Power Station Units 1 and 2. The enclosed report documents the inspection findings, which were discussed on July 27, 2017, with Ms. L. Hilbert and other members of your staff. The inspection team documented the results of this inspection in the enclosed inspection report.
The NRC inspection team reviewed the plants corrective action program and the plants implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the plant was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the inspectors determined that your staffs performance in each of these areas adequately supported nuclear safety.
The inspectors also evaluated the plants processes for use of industry and NRC operating experience information and the effectiveness of the plants audits and self-assessments. Based on the samples reviewed, the inspectors determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the inspectors reviewed the plants programs to establish and maintain a safety-conscious work environment, and interviewed plant personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the inspectors 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. The NRC inspectors did not identify any findings or violations of more than minor significance.
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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Reinaldo Rodriguez, Chief Reactor Projects Branch 7 Division of Reactor Projects Docket Nos. 50-338, 50-339 License Nos. NPF-4, NPF-7
Enclosure:
IR 05000338/2017009 and 05000339/2017009 w/Attachment: Supplemental Information
REGION II==
Docket Nos.: 50-338, 50-339 License Nos.: NPF-4, NPF-7 Report Nos.: 05000338/2017009 and 05000339/2017009 Licensee: Virginia Electric and Power Company Facility: North Anna Power Station, Units 1 and 2 Location: Mineral, VA Dates: July 10 - 14, 2017 July 24 - 27, 2017 Inspectors: N. Staples, Senior Project Inspector, Team Leader D. Piccirillo, Senior Construction Inspector D. Merzke, Senior Reactor Operations Engineer D. Terry-Ward, Construction Inspector Approved by: R. Rodriguez, Chief Reactor Projects Branch 7 Division of Reactor Projects Enclosure
SUMMARY
IR 05000338/2017009 and 05000339/2017009; July 10-14 - July 24-27, 2017; North Anna
Power Station, Units 1 and 2; Biennial Inspection of the Problem Identification and Resolution Report.
The inspection was conducted by a senior project inspector, a senior construction inspector, a senior operations inspector, and a construction inspector. No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6.
Identification and Resolution of Problems The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution, as evidenced by the relatively few number of deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee during the review period. Generally, prioritization and evaluation of issues were adequate, formal root cause evaluations for significant problems were adequate, and corrective actions specified for problems were acceptable. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner.
The inspectors determined that overall, audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the CAP, and appropriate corrective actions were developed to address the issues identified. Operating experience (OE) usage was found to be generally acceptable and integrated into the licensees processes for performing and managing work, and plant operations.
Based on discussions and interviews conducted with plant employees from various departments, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP to resolve those concerns.
REPORT DETAILS
4. OTHER ACTIVIITES
4OA2 Problem Identification and Resolution
.1 Assessment of the Corrective Action Program
a. Inspection Scope
The inspectors reviewed the licensees Corrective Action Program (CAP) procedures which described the administrative process for initiating and resolving problems primarily through the use of condition reports (CRs). To verify that problems were properly identified, appropriately characterized, and entered into the CAP, the inspectors reviewed CRs that had been issued between March 2015 and July 2017, including a detailed review of selected CRs associated with the following risk-significant systems:
High Head Safety Injection (HHSI), Reactor Protection System (RPS), and Reactor Coolant (RC). Where possible, the inspectors independently verified that the corrective actions (CA) were implemented as intended. The inspectors also reviewed selected common causes and generic concerns associated with root cause evaluations (RCE) to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the Reactor Oversight Process (ROP), the inspectors selected a representative number of CRs that were identified and assigned to the major plant departments, including quality assurance, health physics, chemistry, emergency preparedness and security. These CRs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The inspectors reviewed selected CRs, verified corrective actions were implemented, and attended meetings where CRs were evaluated for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.
The inspectors conducted plant walkdowns within the selected systems listed above and other plant areas to assess the material condition and to identify any deficiencies that had not been previously entered into the CAP. The inspectors reviewed CRs, maintenance history, CAs, completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-dependent issues.
Control room walk-downs were also performed to assess the main control room (MCR)deficiency list and to ascertain if deficiencies were entered into the CAP and tracked to resolution. Operator workarounds (OWA) and operator burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the field.
The inspectors conducted a detailed review of selected CRs to assess the adequacy of the cause evaluations of the problems identified. The inspectors reviewed these evaluations against the descriptions of the problem described in the CRs and the guidance in licensee procedure PI-AA-300-3001, Root Cause Evaluation. The inspectors assessed if the licensee had adequately determined the cause(s) of identified problems, and had adequately addressed operability, reportability, common cause, generic concerns, extent-of-condition, and extent-of-cause. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence.
The inspectors reviewed selected industry operating experience (OE) items, including NRC generic communications, to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP.
The inspectors reviewed site trend reports, to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.
The inspectors reviewed licensee audits and self-assessments, including those which focused on problem identification and resolution programs and processes, to verify that findings were entered into the CAP and to verify that these audits and assessments were consistent with the NRCs assessment of the licensees CAP.
The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These meetings included Condition Report Review Team (CRT) and Corrective Action Assignment Review Team (CAART).
Documents reviewed are listed in the Attachment.
b. Assessment Problem Identification The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was an appropriately low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating CRs as described in licensee procedure PI-AA-200, Corrective Action, in addition to managements expectation that employees were encouraged to initiate CRs for any reason. Trending was generally effective in monitoring equipment performance. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues.
Problem Prioritization and Evaluation Based on the review of CRs sampled by the inspection inspectors during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in the CR significance determination guidance in PI-AA-200. Each CR was assigned a priority level at the CR screening meeting, and adequate consideration was given to system or component operability and associated plant risk.
The inspectors determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures and assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used depending on the type and complexity of the issue consistent with procedures.
Effectiveness of Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected and non-recurring. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, CRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence were sufficient to ensure corrective actions were properly implemented and were effective.
c. Findings
No findings were identified.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors examined the licensees use of industry OE to assess the effectiveness of the plant. In addition, the inspectors selected OE documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal OE items, etc.) which had been issued since June 2015, to verify whether the licensee had appropriately evaluated each notification for applicability to the North Anna Power Station, and whether issues identified through these reviews were entered into the CAP. Documents reviewed are listed in the Attachment.
b. Assessment Based on a review of selected documentation related to operating experience issues, the inspectors determined that the licensee was generally effective in screening operating experience for applicability to the plant. Industry OE was evaluated at either the corporate or plant level depending on the source and type of the document. Relevant information was then forwarded to the applicable department for further action or informational purposes. OE issues requiring action were entered into the CAP for tracking and closure. In addition, operating experience was included in all root cause evaluations in accordance with licensee procedure PI-AA-300-3001, Root Cause Evaluation.
c. Findings
No findings were identified.
.3 Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self-assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedure PI-AA-100-1004, Self Assessments.
b. Assessment The inspectors determined that the scopes of assessments and audits were adequate.
Self-assessments were generally detailed and critical, as evidenced by findings consistent with the inspectors independent review. The inspectors verified that CRs were created to document areas for improvement and findings resulting from the self-assessments, and verified that actions had been completed consistent with those recommendations. Generally, the licensee performed evaluations that were technically accurate.
c. Findings
No findings were identified.
.4 Assessment of Safety-Conscious Work Environment
a. Inspection Scope
During the course of the inspection, the inspectors assessed the stations safety-conscious work environment through review of the stations Employee Concerns Program (ECP) and interviews with various departmental personnel. The inspectors reviewed a sample of ECP issues to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.
b. Assessment Based on the interviews conducted and the CRs reviewed, the inspectors determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees.
Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.
c. Findings
No findings were identified.
4OA6 Exit
Exit Meeting Summary
On July 27, 2017, the inspectors presented the inspection results to Ms. Lisa Hilbert and other members of the site staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- W. Belcher, ECP Specialist
- J. Tew, Engineering
- D. McGinnis, Station Licensing
- L. Hembree, Engineering
- J. Schleser, Manager Organization Effectiveness
- L. Hilbert, Plant Manager
- B. Standley, Director Station Safety and Licensing
- A. Dowell, System Engineer - 7300 System
- C. Allmond, Buried Piping Engineer
- A. McEnroe, Maintenance Rule Engineer
- M. Bordeau, Maintenance Rule Engineer
NRC personnel
G.Eatmon, Resident Inspector
LIST OF REPORT ITEMS
Opened and Closed
None
Closed
None
Discussed
None