ML24346A422
| ML24346A422 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 12/11/2024 |
| From: | Hilbert L Virginia Electric & Power Co (VEPCO) |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| EA-24-126, 24-362 | |
| Download: ML24346A422 (1) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 December 11, 2024 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Serial No.:
NAPS/RAP:
Docket No.:
License No.:
24-362 RO 50-339 NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION ENERGY VIRGINIA)
NORTH ANNA POWER STATION UNIT 2 REPLY TO A NOTICE OF VIOLATION; EA-24-126 Pursuant to the provisions of 10 CFR 2.201, Virginia Electric and Power Company (Dominion Energy Virginia) herein provides a reply to NRC Notice of Violation EA 126 dated December 11, 2024.
The required reply to the violation of NRC requirements specified in Notice of Violation EA-24-126 is provided in Attachment 1. This attachment provides: (1) the reason for the violation; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken, and (4) the date when full compliance will be achieved.
Should you have any questions regarding this submittal, please contact Mr. Marcus A.
Hofmann, Manager Nuclear Station Licensing at (540) 894-2100.
Sincerely, ilbert Site Vice President Commitments made in *this letter: None Reply to a Notice of Violation; EA-24-126
cc:
U.S. Nuclear Regulatory Commission Regional Administrator, Region II Marquis One Tower 245 Peachtree Center Avenue, NE, Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector North Anna Power Station Mr. G. E. Miller NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08 E-1 A Rockville, MD 20852-2738 ODEC (Letter Only)
R-North-Anna-Correspondence@odec.com Old Dominion Electric Cooperative
Attachment Serial No.24-362 Docket Nos. 50-339 REPLY TO A NOTICE OF VIOLATION: EA-24-126 Virginia Electric and Power Company (Dominion Energy Virginia)
North Anna Power Station Unit 2
NOTICE OF VIOLATION Serial No.24-362 Docket Nos. 50-339 Attachment, Page 1 of 3 During an NRC inspection conducted from April 18 through November 18, 2024, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is restated below:
Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," states, in part, that "activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. "
The licensee's Nuclear Facility Quality Assurance Program Description, DOM-QA-1, Revision 37, Section 2. 7.1, states, in part, that Dominion Energy shall establish appropriate cleanliness controls for work on safety-related equipment to minimize introduction of foreign material and maintain system/component cleanliness throughout maintenance or modification activities, including documented verification of absence of foreign material prior to system closure.
Procedure 0-EPM-0702-04, "Inspection of EOG 'K' Relays and Contacts," is the governing procedure whose purpose is to "provide instructions for inspection and repair of EOG K relays and contacts. "
North Anna Technical Specifications (TS) Limiting Condition for Operation (LCO) 3.0.1 requires, in part, that LCOs shall be met during the modes of applicability.
TS LCO 3.8.1, "AC Sources," requires, in part, two operable emergency diesel generator (EOG) sets capable of supplying the on site Class 1 E distribution systems; and one EOG capable of supplying the onsite Class 1 E AC distribution system on the other unit for each required shared component while in Modes 1, 2, 3, and 4.
Contrary to the above, on January 13, 2022, the licensee failed to prescribe appropriate documented instructions for an activity affecting the quality of the safety-related Unit 2 'J' (2J) EOG system. Specifically, licensee procedure 0-EPM-0702-04, "Inspection of K Relays and Contacts" did not provide instructions appropriate to the circumstances for foreign material control prior to the assembly and installation of the 2J EOG shutdown and generator field flash relay ("K1 relay"), as evidenced by the foreign material found obstructing the relay contacts which rendered the 2J EOG inoperable from January 18, 2024, to April 19, 2024.
As a result of the 2J EOG 's inoperability, the licensee failed to meet the operability requirements in TS LCOs 3. 0. 1 and 3. 8. 1 for two operable emergency diesel generators on Unit 2 and a diesel capable of supplying shared - components on Unit 1 while in MODE 1. Once the EOG inoperability was identified on April 18,
Serial No.24-362 Docket Nos. 50-339 Attachment, page 2 of 3 2024, the licensee took appropriate corrective actions to restore EOG operability within the completion times established in TS 3. 8. 1.
This violation is associated with a White Finding.
RESPONSE TO THE NOTICE OF VIOLATION
- 1. Reason for Violation On 4/18/2024, during the performance of 2J Emergency Diesel Generator (EOG) surveillance testing (2-PT-82.2B) the electrical generator failed to flash the field resulting in the EOG being declared inoperable. Follow-up inspections identified foreign material (FM) located in the K1 relay which prevented the component from performing its design function (allowing field to flash).
A Root Cause Evaluation determined that there was inadequate rigor for foreign material controls in the Legacy Design Change Process in 2008. The process failed to address FM as a design consideration which caused the selected and installed design for the K1 relay in the 2J EOG to be susceptible to FM. Contributing, North Anna failed to provide detailed special instructions in the electrical maintenance procedure (Inspection of EOG "K" relays and contacts, 0-EPM-0702-04) for foreign material exclusion (FME) to support the 2J EOG K1 relay assembly, testing, inspection and installation.
- 2. Corrective Steps That Have Been Taken and the Results Achieved The following corrective actions have been taken:
Revised the Design Attributes Review Checklist (DNES-AA-GN-1003, ) to include general design consideration for modifications that are susceptible to foreign material.
Implemented special modification considerations and controls concerning foreign material susceptibility for the current K1 relay design, with respect to testing and installation activities.
Implemented special modification considerations and controls concerning foreign material susceptibility for the current K1 relay design, with respect to warehouse instructions for receipt, handling, and storing activities.
These changes were reinforced with warehouse personnel.
Revised electrical maintenance procedure, 0-EPM-0702-04, to include special foreign material inspection instructions sufficient for the K1 relay.
Serial No.24-362 Docket Nos. 50-339 Attachment, page 3 of 3 Revised MS-AA-WHS-136, Supply Chain Management Foreign Material Inspection and Intrusion Prevention, to include an appropriate reference for storage expectations and require warehouse documentation of FM observations.
The 2J EOG Field Flash/ Shutdown Relay K1 was replaced at the time of the event, on 4/19/24. Subsequently, special foreign material inspections were performed on all 4 EOG K1 relays. No foreign material was discovered during these inspections.
Performed a sampling of safety related (SR) relays in storage to ensure storage requirements were being met with no issues identified.
- 3. Corrective Steps That Will be Taken Additional corrective actions are planned:
Establish formal FM observation documentation for warehouse activities.
Invoke vendor surveillance for future purchases of existing K1 relay design.
Evaluate replacement design of K1 relays that are not susceptible to FM intrusion.
Additional corrective actions, in accordance with the root cause evaluation, will be completed accordingly.
- 4. The Date When Full Compliance Will be Achieved Full compliance was achieved when the corrective actions identified in Section 2 were completed and approved by the Corrective Action Review Board on December 5, 2024.
Operability of the 2J EOG was restored on April 19, 2024.