ML25126A012
| ML25126A012 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/07/2025 |
| From: | James Baptist NRC/RGN-II/DORS/PB4 |
| To: | Carr E Dominion Energy |
| References | |
| IR 2025001 | |
| Download: ML25126A012 (1) | |
Text
Eric S. Carr President, Nuclear Operations Chief Nuclear Officer Dominion Energy Innsbrook Technical Center 5000 Dominion Blvd., Floor: IN-3SE Glen Allen, VA 23060-6711
SUBJECT:
NORTH ANNA POWER STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000338/2025001 AND 05000339/2025001
Dear Eric S. Carr:
On March 31, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at North Anna Power Station, Units 1 and 2. On April 22, 2025, the NRC inspectors discussed the results of this inspection with Lisa Hilbert, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. Two of 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.
If you contest the violations or the significance or severity of the violations 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.
May 7, 2025
E. Carr 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, James B. Baptist, Chief Projects Branch 4 Division of Operating Reactor Safety Docket Nos. 05000338 and 05000339 License Nos. NPF-4 and NPF-7
Enclosure:
As stated cc w/ encl: Distribution via LISTSERV Signed by Baptist, James on 05/07/25
SUNSI Review x
Non-Sensitive
Sensitive x
Publicly Available
Non-Publicly Available OFFICE RII/DORS RII/DORS RII/DORS NAME C. Even K. Carrington J. Baptist DATE 5/07/25 5/07/25 5/07/25
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Numbers:
05000338 and 05000339 License Numbers:
NPF-4 and NPF-7 Report Numbers:
05000338/2025001 and 05000339/2025001 Enterprise Identifier:
I-2025-001-0027 Licensee:
Dominion Energy Facility:
North Anna Power Station, Units 1 and 2 Location:
Mineral, VA Inspection Dates:
January 01, 2025, to March 31, 2025 Inspectors:
K. Carrington, Senior Resident Inspector C. Even, Senior Project Engineer J. Lizardi-Barreto, Reactor Inspector D. Turpin, Resident Inspector Approved By:
James B. Baptist, Chief Projects Branch 4 Division of Operating Reactor Safety
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated 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 Control Transient Combustibles in Accordance with the North Anna Fire Protection Program Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000339/2025001-01 Open/Closed
[H.4] -
Teamwork 71111.05 The inspectors identified a finding of very low safety significance (Green) and an associated Non-cited Violation (NCV) of Technical Specifications 5.4, "Procedures," Section 5.4.1, for the licensee's failure to implement the North Anna fire protection program in accordance with Technical Requirements Manual Section 7.2 and Dominion Procedure CM-AA-FPA-101.
Specifically, from January 15 to February 10, 2025, the licensee failed to control and implement compensatory measures for transient combustibles stored in a restricted area of the Unit 2 normal switchgear room.
Failure to Have A Procedure Appropriate to the Circumstances Results in 1H EDG Inoperability Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000338/2025001-02 Open/Closed
[H.1] -
Resources 71153 A finding of very low safety significance (Green) and an associated non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," and Technical Specifications 3.8.1, "AC Sources-Operating," was self-revealed on October 9, 2024, when the Unit 1, 'H' (1H) emergency diesel generator (EDG) was secured after failing to achieve rated speed and frequency during its quarterly surveillance test. Specifically, the licensee failed to prescribe appropriate instructions for ensuring the 1H EDG governor vernier was placed at its high-speed stop setting, an activity affecting quality, following manipulation or performance of other activities that could impact diesel reliability.
Additional Tracking Items Type Issue Number Title Report Section Status LER 05000338/2024-001-01 LER 2024-001-01 for North Anna Power Station Unit 1 Automatic Reactor Trip due to PRNI High Negative Rate 71153 Closed
3 LER 05000338/2024-001-00 LER 2024-001-00 for North Anna Power Station, Unit 1, Automatic Reactor Trip due to PRNI High Negative Rate 71153 Closed LER 05000338/2024-002-01 LER 2024-002-01 for North Anna Power Station, Unit 1, IH EDG Failure to Achieve Rated Speed / Frequency During Surveillance Testing 71153 Closed LER 05000338/2024-002-00 LER 2024-002-00 for North Anna Power Station, Unit 1, 1H EDG Failure to Achieve Rated Speed / Frequency during Surveillance Testing 71153 Closed
4 PLANT STATUS Unit 1 operated at or near 100 percent rated thermal power (RTP) for the entire inspection period.
Unit 2 began the inspection period operating at or near 100 percent RTP. On March 1, 2025, the unit was shut down for refuel outage 2R30. The unit remained shut down through the end of the inspection period.
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 performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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 71111.01 - Adverse Weather Protection Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather for heavy snowfall, from January 5-10, 2025.
71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)
Unit 1 'H' emergency diesel generator (EDG) system following testing, on January 10, 2025 (2)
Unit 2 'A' and 'B' residual heat removal system prior to draining reactor water level below the reactor vessel flange, on March 4, 2025 (3)
Unit 1 and Unit 2 shared spent fuel pit cooling system following Unit 2 core offload, on March 21, 2025 (4)
Unit 2 'J' EDG system following testing, on March 21, 2025 71111.05 - Fire Protection Fire Area Walkdown and Inspection Sample (IP Section 03.01) (7 Samples)
5 The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
(1)
Fire Area 5-1, Unit 1 normal switchgear room, on February 7, 2025 (2)
Fire Area 5-2, Unit 2 normal switchgear room, on February 7, 2025 (3)
Fire Area 11, auxiliary building, 291' elevation, on March 26, 2025 (4)
Fire Area 11, auxiliary building, 274' elevation, Unit 2 volume control tank cubicle, on March 28, 2025 (5)
Fire Area 11, auxiliary building 259' elevation, demineralization alley, on March 28, 2025 (6)
Fire Area 11, auxiliary building, 244' and 259' elevations, 'A' and 'B' gas stripper rooms, on March 28, 2025 (7)
Fire Areas 1-2, Unit 2 containment anulus (all elevations) on March 31, 2025 Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated onsite fire brigade training and performance during an announced fire drill in the Unit 1 turbine building, on February 6, 2025.
71111.08P - Inservice Inspection Activities (PWR)
The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary were appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities in Unit 2 during refueling outage 2R30 from March 10 to March 14, 2025.
PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01) (1 Sample)
The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:
(1)
Ultrasonic Examination 1.
SI System, 3-SI-539, weld SW-81, elbow to pipe, American Society of Mechanical Engineers (ASME) Class 1 2.
SI System, 3-SI-539, weld SW-83, elbow to pipe, ASME Class 1 Visual Examination 1.
VT-1 of 2-RC-E-1B, SGB, S/G support welds, ASME Class 1 2.
VT-3 of 2-RC-R-1, RX, Baffle-Former Bolts with Indications, ASME Class 1 3.
VT-3 of 2-RC-R-1, RX, Thermal Shield Support Block Bolting, ASME Class 1 Welding Activities 1.
Gas Tungsten Arc Welding, a.
RC System, 02-RC-1097-VALVE, installation socket welds number 114 and 115, on 3/4" line number RC-571-153A-Q3, ASME Class 3 (WO 59203456063)
6 PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)
The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:
(1) 1.
Boric Acid Walkdown - March 12, 2025 1.
New Boric Acid condition reports (CRs) from NRC walkdown a.
CR 1285652 1.
Boric Acid Engineering Evaluations a.
CR 1253071 b.
CR 1278645 c.
CR 1284533 d.
CR 1284535 e.
CR 1284536 f.
CR 1284949 g.
CR 1284520 h.
CR 1284524 71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)
(1)
The inspectors observed and evaluated licensed operator performance in the main control room during a Unit 1 power ascension following entry into an abnormal operating procedure associated with degrading condenser vacuum, on February 11, 2025.
(2)
The inspectors observed and evaluated licensed operator performance in the main control room during the Unit 2 shutdown for refuel outage 2R30, on March 2, 2025.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)
(1)
The inspectors observed and evaluated licensed operator requalification exams and job performance measures (JPMs), on February 14, 2025.
(2)
The inspectors observed and evaluated just-in-time training for the Unit 2 refueling outage, on February 28, 2025.
71111.12 - Maintenance Effectiveness Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following structures, systems, and components (SSC) remain capable of performing its intended function:
(1)
New Fuel Receipt for Unit 2, batch 33
7 71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
(1)
Risk mitigating actions and emergent troubleshooting of Unit 1 loss of condenser vacuum, 2J EDG planned maintenance, 530 KV bus 1 maintenance, and winter storm advisory, the week of February 11, 2025 (2)
Unit 1 and Unit 2 increased online risk during 530 kV switchyard bus no. 1 outage; Pennsylvania, Jersey, and Maryland (PJM) conservative grid operations and winter storm advisory; Unit 2 reactor coolant filter changeout; and Unit 2 'A' motor generator (MG) increased vibrations, the week of February 19, 2025 (3)
Unit 2 increased shutdown risk (yellow) during reactor water level drain down activities to reduced inventory (pressurizer level 5 percent and reactor water level 74 inches above flange), from March 4-5, 2025 (4)
Unit 1 online risk change to yellow during Unit 2 feedwater heater replacement and heavy lift, the week of March 9, 2025 71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1)
Design changes NA-19-01155 and NA-19-01156, Unit 1 and Unit 2 Refueling Water Chemical Addition Tank (CAT) Removal and Sodium Hydroxide (NaOH) pH Buffer Elimination, on February 5, 2025 71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01) (1 Partial)
(1)
(Partial)
The inspectors evaluated refueling outage 2R30 activities (IP 71111.20, Sections a, b, and c1-c12), from March 1 to March 31, 2025.
71111.24 - Testing and Maintenance of Equipment Important to Risk The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (4 Samples)
(1)
'A' spent fuel pit cooling pump PMT following oil leak repair under WO59203391593, on January 28, 2025
8 (2)
Unit 2, 'J' emergency diesel generator PMT following planned maintenance under WO59203385714, on February 14, 2025 (3) 1-HV-E-4A, following piping replacement under WOs 59203374465, 59203369684, 59203374462, and 59203403135, on February 15, 2025 (4)
Unit 2, 'J' emergency diesel generator PMT following planned maintenance under WO59102112816, on March 18, 2025 Surveillance Testing (IP Section 03.01) (5 Samples)
(1) 2-PT-71.2Q, Unit 2, 2-FW-P-3A, 'A' Motor Driven AFW Pump, and Valve Test, on January 2, 2025 (2) 2-PT-31.2.1, Reactor Coolant System Temperature Instrumentation Calibration (T-2412) Protection Channel 1, on January 28, 2025 (3) 0-PT-82.14, SBO Diesel Generator Test (Start by Simulated LORSS [loss of reserve station service] Power), on January 28, 2025 (4) 2-PT-83.1, Simulated Loss of Offsite Power (LOOP) and ESF actuation - H Bus, on March 3, 2025 (5) 2-PT-83.4H, Loss of Offsite Power (LOOP) on 2H Bus for Shutdown Loads, on March 3, 2025 Inservice Testing (IST) (IP Section 03.01) (1 Sample)
(1) 2-PT-71.3Q.1, 2-FW-P-3B, Motor Driven AFW IST Comprehensive Pump and Valve Test, on January 14, 2025 Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)
(1) 2-PT-61.3, Containment Type C Test [Penetration 25], on March 6, 2025 71114.06 - Drill Evaluation Required Emergency Preparedness Drill (1 Sample)
(1)
The inspectors observed licensee performance of simulated DEP scenario NFADS+L-MA6.1 for state and local communications, on January 16, 2025.
Additional Drill and/or Training Evolution (1 Sample)
The inspectors evaluated:
(1)
The inspectors observed licensee performance of non-DEP training drill scenario NJAN25TD in the control room simulator and technical support center, on January 14, 2025.
OTHER ACTIVITIES - BASELINE 71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (2 Samples)
9 (1)
Unit 1: Unplanned Scrams per 7,000 Critical Hours (January 1 to December 31, 2023)
(2)
Unit 2: Unplanned Scrams per 7,000 Critical Hours (January 1 to December 31, 2023)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2 Samples)
(1)
Unit 1: Unplanned Power Changes per 7000 Critical Hours (January 1 to December 31, 2023)
(2)
Unit 2: Unplanned Power Changes per 7000 Critical Hours (January 1 to December 31, 2023)
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)
(1)
Unit 1: Unplanned Scrams with Complications (January 1 to December 31, 2023)
(2)
Unit 2: Unplanned Scrams with Complications (January 1 to December 31, 2023) 71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02) (2 Samples)
The inspectors evaluated the following licensee event reports (LERs) and updated submittals:
(1)
LER 05000338/2024-001-00 (01), Unit 1 Automatic Reactor Trip due to PRNI High Negative Rate (ADAMS Accession No. ML24268A312). The inspectors determined that the condition described in the LER was not reasonably within the licensee's ability to foresee and correct and therefore was not preventable. No performance deficiency nor violation of NRC requirements was identified. This LER and its associated supplement are closed.
(2)
LER 05000338/2024-002-00 (01), Unit 1, 1H EDG Failure to Achieve Rated Speed /
Frequency During Surveillance Testing (ADAMS Accession No. ML25043A286). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section IP 71153. One non-cited violation of NRC requirements was identified. This LER and its associated supplement are closed.
INSPECTION RESULTS Failure to Control Transient Combustibles in Accordance with the North Anna Fire Protection Program Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000339/2025001-01 Open/Closed
[H.4] -
Teamwork 71111.05 The inspectors identified a finding of very low safety significance (Green) and an associated Non-cited Violation (NCV) of Technical Specifications 5.4, "Procedures," Section 5.4.1, for the licensee's failure to implement the North Anna fire protection program in accordance with Technical Requirements Manual Section 7.2 and Dominion Procedure CM-AA-FPA-101.
Specifically, from January 15 to February 10, 2025, the licensee failed to control and
10 implement compensatory measures for transient combustibles stored in a restricted area of the Unit 2 normal switchgear room.
==
Description:==
On February 7, 2025, the inspectors performed a walkdown of the Unit 2, normal switchgear room. During the walkdown, the inspectors noted a combustible loading permit associated with work order (WO) 59203417937 that was posted to the normal switchgear room's east wall leading to Unit 1 that had been active since January 15, 2025. The inspectors reviewed the permit to determine any allowances for or evaluations of transients in the room. During their review, the inspectors noted Dominion procedure CM-AA-FPA-101, "Control of Combustibles and Flammable Materials," Attachment 8, "Table A8-1:
North Anna Power Station - Transient Combustible Loading Limits and Restrictions," listed restricted areas within the Unit 2 normal switchgear room in which no transient combustibles were allowed to be stored. Specifically, the procedure required no transient combustible be stored within 5 feet of any floor penetration seal, nor within 10 feet of any wall/door for the Unit 2 normal switchgear room. Contrary to this requirement, the inspectors identified a transient within 5 and 10 feet of the restricted areas of the room.
The inspectors questioned the licensee on the acceptability of the transient combustibles, given the associated fire permit did not evaluate or provide justification for allowance of the identified transient combustible in the restricted areas of the room. Following the inspectors' questions, the licensee performed a walk down of the Unit 2 normal switchgear room and observed the placement of the transient combustible. Subsequently, on February 10, 2025, the licensee removed/modifed the placement of the combustible.
Based on the identified combustible being stored within the restricted areas of the Unit 2 normal switchgear room (Fire Door 1-BLD-STR-S07-3, an adjacent fire wall, and adjacent fire penetration seals), the licensee determined a shiftly fire watch would have been required. The inspectors concluded that storage of combustibles without an appropriate permit or the pre-establishment of compensatory measures did not meet the requirements in CM-AA-FPA-101 and North Anna Technical Requirements Manual (TR), Section 7.2, "Fire Barriers, Penetration Seals, Fire Doors, and/or Fire Dampers," and therefore constituted a failure of the station to implement and maintain the provisions in the North Anna fire protection program.
Corrective Actions: The licensee immediately implemented a shiftly fire watch and took action to remove or store the transients in a fire-rated enclosure.
Corrective Action References: CR1282710 Performance Assessment:
Performance Deficiency: The inspectors determined the licensee's failure to implement the North Anna fire protection program in accordance with CM-AA-FPA-101, "Control of Combustible and Flammable Materials," and TRM Section 7.2, "Fire Barriers, Penetration Seals, Fire Doors, and /or Fire Dampers," which resulted in the storage of transient combustibles within a restricted area of the Unit 2 normal switchgear room without a pre-established fire watch was within the licensee's ability to foresee and correct and was therefore a performance deficiency.
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 storage of transient combustibles in a restricted
11 area of the Unit 2 normal switchgear room without the presence of a fire watch or compensatory measures in place had the potential to increase the risk of a fire in the area.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors assessed the finding using the qualitative screening questions associated with fire categories 1.4.1, "Fire Prevention and Administrative Controls," and 1.4.4, "Fire Confinement."
Under Question 1.4.1, the inspectors concluded the finding would not have increased the likelihood of a fire nor could have resulted in a more significant fire than previously analyzed; however, the finding could delay detection of a fire with no watch present. Specifically, fire watches provide early detection and suppression capability prior to actuation of automatic suppression and detection features. Therefore, the inspectors answered "Yes" to Question 1.4.1.A and conducted further analysis of the finding under Question 1.4.1.B. Under Question 1.4.1.B, the inspectors concluded that adequate automatic fire detection and suppression was available in adjacent fire areas; therefore, the finding screened to GREEN.
The inspectors then assessed the finding under Question 1.4.4 and concluded that since fire elements would have continued to provide adequate fire endurance to prevent fire propagation through fire confinement based on the combustible loading in the area having remained below limits, the finding screened to GREEN.
The inspectors determined the finding was also similar to More than Minor Example 4.j of IMC 0612, Appendix E, "Examples of Minor Issues," dated 10/26/2023, in that the identified transient had the potential to affect a combustible free zone's function to prevent fire propagation or spread.
Cross-Cutting Aspect: H.4 - Teamwork: Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, communications between work groups related to ongoing activities did not occur to allow evaluation of transient combustibles in the restricted area of the Unit 2 normal switchgear room. This breakdown in communications led to no compensatory measures or a fire watch being established in the room.
Enforcement:
Violation: Technical Specifications 5.4, "Procedures," Section 5.4.1 requires, in part, that written procedures shall be established, implemented, and maintained covering Fire Protection Program implementation.
Dominion Procedure CM-AA-FPA-101, "Control of Transient Combustibles," and North Anna Technical Requirements Manual (TRM), Section 7.2, "Fire Barriers Penetration Seals, Fire Doors and/or Fire Dampers," Fire Protection cover implementation of the North Anna Fire Protection program.
CM-AA-FPA-101, Attachment 8, states in part, no transient within 10 feet of Fire Door 1-BLD-STR-S07-3 (listed in Appendix R Report Table 2.1), nor within 10 feet of any associated adjacent wall, nor within 5 feet of any associated fire penetrations inside the Unit 2 normal switchgear room.
TRM Section 7.2, states in part, all fire barriers, penetration seals, fire doors separating fire areas listed in NAPS Appendix R Report Table 2.1 shall be Functional or a fire watch shall be
12 established for the affected fire barriers, penetration seals, fire doors, or fire dampers.
Contrary to the above, from January 15, 2025 to February 10, 2025, the licensee failed to implement and maintain in effect, the provisions of the approved fire protection program as described in CM-AA-FPA-101 and TRM Section 7.2, resulting in a shiftly fire watch not being implemented when a combustible transient was stored within restricted areas of the Unit 2 normal switchgear room.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Have A Procedure Appropriate to the Circumstances Results in 1H EDG Inoperability Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000338/2025001-02 Open/Closed
[H.1] -
Resources 71153 A finding of very low safety significance (Green) and an associated non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," and Technical Specifications 3.8.1, "AC Sources-Operating," was self-revealed on October 9, 2024, when the Unit 1, 'H' (1H) emergency diesel generator (EDG) was secured after failing to achieve rated speed and frequency during its quarterly surveillance test. Specifically, the licensee failed to prescribe appropriate instructions for ensuring the 1H EDG governor vernier was placed at its high-speed stop setting, an activity affecting quality, following manipulation or performance of other activities that could impact diesel reliability.
==
Description:==
North Anna Power station has two emergency diesel generators per unit. The emergency diesels function as alternate sources of emergency power during design basis accidents or loss of offsite power events. Each emergency diesel is rated for a particular engine speed, frequency, and voltage, vital to accomplishing its function. The frequency and engine speed are controlled by an electronic governor that maintains primary control of engine speed at a rated 900 RPM and steady state frequency at 60 Hz. Each diesel engine also has a mechanical governor that serves as the back up control unit and is equipped with manual speed control via a speed control knob or vernier position indicator, along with a mechanical slow speed and high-speed stop device. The control unit that ultimately exercises control over EDG engine speed and frequency is the one set with the lowest operating speed setting.
The mechanical slow speed stop is set to approximately 500 RPM and the mechanical high-speed stop is set to 945 RPM (equivalent to 63 Hz). When the EDGs are in AUTO or a standby configuration, the mechanical governor vernier speed setting is set at a dial setting of 945 RPM (high-speed stop). This configuration allows the primary control unit or electronic governor to be in control of the system at 900 RPM.
On October 9, 2024, the licensee commenced performance of 1-PT-82.2A, "1H EDG Fast Start surveillance." Upon starting the diesel, the operators in the main control room noted an abnormal condition in which they were unable to adjust the 1H EDG speed or achieve steady state frequency within the Technical Specifications. Specifically, the maximum achievable frequency and engine speed were 58.5 Hz and 880 rotations per minute (rpm), respectively, versus a rated engine speed of 900 rpm and TS-required frequency band of 59.5 to 60.5 Hz.
13 As a result, the diesel was secured. The diesel had previously been declared inoperable for performance of the surveillance and remained inoperable due to the identified condition.
Licensee troubleshooting and investigation identified the 1H EDG governor's high speed stop setting was too low. Specifically, the governor vernier's high speed stop as-found setting was 18.74 compared to a normal setting of 21.90. With the 1H EDG mechanical governor speed control found at 18.74 and engine operating at 880 RPM/ 58.5 Hz, the mechanical governor maintained control of the engine speed since it was below the 900 RPM control point of the electronic governor. Consequently, the 1H EDG operated outside the minimum Technical Specification frequency requirements and UFSAR setpoints and prevented the diesel from being able to be synchronized to offsite power. Following identification of the condition, the licensee adjusted the governor vernier high speed stop setting to 21.90. On October 10, 2024, following correction of the abnormal condition and successful performance of the 1H EDG fast start surveillance, the 1H EDG was declared operable. Due to the as-found condition of the 1H emergency diesel not being able to achieve its TS-required frequency, the licensee concluded that this condition met the criteria for consideration as a licensee event reportable to the NRC under 10 CFR 50.73(a)(2)(i)(B) for Operation or Conditions Prohibited by Technical Specifications.
A past operability review and engineering evaluation was subsequently performed to determine the cause of the high speed stop setting being set too low and the implications on past operability of the 1H EDG.
Licensee evaluation CA12989990 revealed a potential cause to be human error resulting in mispositioning of the vernier to the incorrect setting which potentially occurred during the last EDG slow start surveillance in July 2024. In their evaluation, the licensee acknowledged that no procedure was in place to routinely verify the EDG governor speed settings in order to ensure they were placed in the proper position following testing or manipulation.
The licensee's operability evaluation further determined the EDG would have been capable of auto-starting, supplying onsite power to its associated emergency bus, and maintaining all safety-related design basis electrical loads; therefore, the licensee concluded that while the diesel would have been inoperable due to failing to meet the TS surveillance requirement for achieving steady-state frequency, ultimately, there would have been no impact to the accident analysis.
The inspectors reviewed the history of the EDG to determine the last time the diesel governor vernier setting was potentially manipulated and identified the last documented manipulation of the 1H EDG governor occurred during the 1H EDG slow start surveillance (1-PT-82.9H, "1-EE-EG-1H Local Operation"), on July 9, 2024. This time stamp coincided with the timeline the licensee developed in its level of effort evaluation. During that surveillance, the diesel vernier setting was found at 20.96, however the procedure did not provide any steps to verify or check that the EDG was returned to its high-speed setting following completion of the surveillance. Consequently, the EDG vernier setting was not verified again until the 1H EDG failed its surveillance on October 9, 2024. The inspectors determined the licensee had multiple opportunities to identify the governor vernier high speed stop setting was incorrect since routine walkdowns of the diesels are also performed. However, the inspectors also noted that these procedures also failed to contain instructions for verifying the EDG governor vernier settings.
Based on their review, the inspectors determined the last known performance of any
14 maintenance and testing for the 1H EDG was July 9, 2024. The inspectors determined this date to be the last documented evidence of meeting the TS surveillance requirement that the emergency diesel generators be capable of achieving a steady state frequency of 59.5 Hz to 60.5 Hz. Therefore, the inspectors considered that the TS LCO 3.8.1 to have been unmet since July 2024, TS SR 3.0.1 states, in part, SRs shall be met during the MODES or other specified conditions in the Applicability and failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO."
Corrective Actions: The licensee adjusted the governor vernier for 1H EDG high speed stop to the correct setting and established corrective actions to revise various procedures and operator rounds to include shiftly verification of EDG vernier settings.
Corrective Action References: CA12989990 Performance Assessment:
Performance Deficiency: The licensees failure to prescribe documented instructions appropriate to the circumstances for verifying or ensuring the Unit 1 'H' (1H) emergency diesel generator (EDG) governor vernier was at the high-speed stop setting, was within the licensee's ability to foresee and correct, and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality 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 have procedural instructions for placing the diesel in its standby configuration had the potential to affect the diesel's ability to perform its design basis function.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the finding in accordance with Appendix A, Exhibit 2- "Mitigating Screening Questions." The inspectors initially answered yes to Question 3, "Does the degraded condition represent a loss of PRA function of one train of a multi-train Technical Specification (TS) system for greater than the TS-allowed outage time [14 days]," and determined a detailed risk evaluation by a senior reactor analyst (SRA) was warranted.
To assist in their risk determination, the inspectors and SRA reviewed the licensee's evaluation that determined the degraded condition would not have resulted in a loss of PRA or safety function of the 1H EDG. Specifically, the licensee considered that "the EDG is normally analyzed at 60.5 Hz. This is due to the higher frequency increases in the demand of Brake Horsepower (BHP) which in turn increases the realized KW loading of the bus. The most heavily loaded EDG is 1H which normally has a Technical Specification limit analyzed loading of 3342 KV (2966 KW). This results in a running current of 438.5A. Accounting for the deviation in frequency to 58.5 Hz, the running load of the EDG is reduced to 2999 KV (2620 KW). This results in a running current of 393.5A. The EDG's rated continuous load current is noted as 520A. Therefore, the expected loading of the bus at 58.5 Hz is bound by North Anna specific calculations and would pose no operational challenges to the EDG's ability to carry bus loads. The 1H EDG would have auto started, output breaker closed, electrical loads sequenced on the bus, and the engine, electrical generator, voltage regulator, and governor controls would have functioned supporting continuous operation at 58.5 Hz. Additionally,
15 there would be no impact to the design basis safety analysis for a Large Break Loss of Coolant Accident (LBLOCA), and no adverse impact to the PRA Success criteria for this event."
Based on their review, the SRA concluded that at the reduced frequency the 1H EDG would still have the capability to start, and sequence following a load shed, and that the safety-related emergency core cooling system loads would be capable of producing adequate flow; therefore, the PRA function would be maintained. The inspectors also verified that sufficient procedures existed to credit recovery actions for identification of the degraded condition.
Based on this information, the inspectors reassessed the finding in accordance with IMC 0609, Appendix A, Exhibit 2 and answered "no" to all of the questions in the exhibit; therefore, the finding screened to GREEN.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.
Specifically, the licensee failed to ensure procedures were adequate for verifying diesel operability following testing or other activities that may potentially impact diesel reliability.
Enforcement:
Violation: 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings,"
requires, 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. Instructions procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
North Anna Technical Specifications Surveillance Requirement (SR) 3.0.1 states in part, SRs shall be met during the MODES or other specified conditions in the Applicability. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO.
TS LCO 3.0.1 requires, in part, that LCOs shall be met during MODES of applicability. TS LCO 3.8.1, AC Sources-Operating, requires, in part, two operable emergency diesel generator (EDG) sets capable of supplying the onsite Class 1E distribution systems; and one EDG capable of supplying the onsite Class 1E AC distribution system on the other unit for each required shared component while in MODES 1, 2, 3, and 4.
Contrary to the above, prior to October 10, 2024, the licensee failed to have a procedure appropriate to the circumstances for prescribing an activity affecting the quality of the safety-related 1H EDG system. Specifically, licensee procedures did not provide instructions for verifying the 1H EDG governor vernier setting resulting in the licensee's failure to identify the high-speed stop was at the incorrect setting. Consequently, the licensee failed to meet TS SR 3.0.1, and TS LCOs 3.0.1 and 3.8.1, from July 9, 2024, to October 10, 2024. Once the condition was identified on October 9, 2025, the licensee took appropriate corrective actions to restore EDG operability.
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
16 The inspectors verified no proprietary information was retained or documented in this report.
On April 22, 2025, the inspectors presented the integrated inspection results to Lisa Hilbert, Site Vice President, and other members of the licensee staff.
On March 14, 2025, the inspectors presented the Exit Meeting inspection results to Lisa Hilbert, Site Vice President, and other members of the licensee staff.
17 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date 021-247-287 Krautkramer Transducers' Certificate of Conformity Serial #
01CP6Y, 01CWK3 D
113224591 Baker Hughes Transducers' Certificate of Conformity Serial #
19J00C0Y, 19I024HE 10/14/2019 2025-00272 Newco Calibration Certificate NDT-003 1/15/2025 LN-25-002 Ultrasonic Instrument Linearity Report Serial #
140723507/M18207SP/08-4345 9
Order #
70161843 Certification of Conformance for Flawed Specimens # CB-02-217, -218, -219 10/10/06 Calibration Records P.O.# 5920 Certification for Calibration Block 05-6535 12/13/2005 Drawings 12050-RC-2571B Erection Control Isometric Sheets 1 thru 3 Rev. 35 Miscellaneous Batch# 22G057 Certificate of Compliance for Ultragel II 7/26/2022 UT-25-015 UT Calibration/Examination for 12050-WMKS-0103AJ-2/3-SI-539/SW-81 3/12/2025 UT-25-016 UT Calibration/Examination for 12050-WMKS-0103AJ-2/3-SI-539/SW-83 3/12/2025 VT-25-008 Visual Examination of Welds (VT-1) 12050-WMKS-RC-E-1B.1 / 2-RC-E-1B / SGB 3/12/2025 VT-25-034 Visual Examination of Reactor Vessel and Internals (VT-3) 12050-WMKS-RC-R-1.1 / 2-RC-R-1 / Thermal Shield Support Block Bolting 3/11/2025 NDE Reports VT-25-038 Visual Examination of Reactor Vessel and Internals (VT-3) 12050-WMKS*RC-R-1.1 / 2-RC-R-1 / Baffle-Former Bolts With Indications 3/14/2025 Procedures ER-AA-NDE-UT-802 Ultrasonic Examination of Austenitic Piping Welds in Accordance with ASME Section XI, Appendix VIII 9
71111.08P Work Orders 59203456063 Installation Valve on line 3/4" RC-571-153A-Q3 3/13/2025 71111.24 Procedures 2-PT-71.2Q 2-FW-P-3A, A Motor-Driven AFW Pump, and Valve Test 49