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| Quarter | Site | Title | Description | |
|---|---|---|---|---|
| 05000338/FIN-2012004-01 | 2012Q4 | North Anna | Failure to Promptly Identify and Correct a Condition Adverse to Quality Involving Inadequate Tornado Missile Protection for a Pipe Penetration in the SWPH | The inspectors identified a non-cited violation of 10CFR 50, Appendix B, Criterion XVI, Corrective Action , for the failure to promptly identify and correct a condition adverse to quality associated with inadequate tornado missile protection for a vent line penetration into the service water pump house (SWPH). The licensee initiated condition report CR479566, SWPH Tornado Missile Protection Vulnerability, installed a temporary missile shield, and initiated design change NA-12-00056 to implement long-term corrective action. The inspectors reviewed the issue of concern in accordance with IMC 0612, Appendix B, Issue Screening. The inspectors determined that the failure to identify and correct a condition adverse to quality associated with inadequate tornado missile protection for pipe penetrations into the SWPH was a performance deficiency (PD). The PD is more than minor, and therefore a finding, because it adversely affected the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and the related attribute of protection against external events. . Specifically, a tornado could potentially affect the operation of one train of the safetyrelated SWPH ventilation system due to inadequate tornado missile protection for pipe penetrations. The inspectors evaluated the finding using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, because the affected system, service water, supports long term heat removal. The inspectors determined that the finding was of very low safety significance, Green, because it did not represent an actual loss of function of one or more non-technical specification required trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hrs. In addition, this finding involved the cross-cutting area of problem identification and resolution, the component of the corrective action program, and the aspect of, evaluation of identified problems, P.1(c), because the licensee failed to identify inadequate tornado missile protection for a pipe penetration into the SWPH during multiple extent of condition evaluations. |
| 05000338/FIN-2012004-02 | 2012Q4 | North Anna | Challenges to Personnel Accountability Following Declared Alert | The inspectors identified a self-revealing Green finding for the licensees failure to follow posted manual personnel accountability instructions, which resulted in delays in completing the accounting process. Specifically, the licensee failed to perform manual accountability as expected which required locating a large number of individuals reported as missing thereby causing delays in completing the personnel accounting process. The licensee\'s Emergency Plan Implementing Procedure (EPIP) 1.03, Response to Alert, instructed the Station Emergency Manager to verify all personnel are accounted for in accordance with EPIP 5.03, Personnel Accountability, which instructed Security personnel to maintain continuous protected area accountability until event termination. Accountability system card-readers normally used to establish and maintain continuous personnel accountability were unavailable, and some assembly area leaders were not familiar with instructions posted in assembly areas for manual accountability of personnel. The degraded manual personnel accounting process resulted in expending over four hours to locate a large number of individuals reported as missing. The licensee entered the issue into their corrective action program as condition report, CR-439343. The inspectors determined that the licensees failure to follow posted manual personnel accountability instructions was a performance deficiency. The performance deficiency was determined to be more than minor because it adversely impacted the Emergency Preparedness Cornerstone attribute of Emergency Response Organization Performance. The finding impacted the cornerstone objective because it is associated with actual event response. The finding was assessed for significance in accordance with NRC Inspection Manual Chapter (IMC) 0609, using the Phase I SDP worksheets for emergency preparedness and IMC 0609 Appendix B and was determined to be of very low safety significance (Green) because the finding was not associated with an emergency preparedness planning standard. The cause of this finding involved the cross-cutting area of human performance, the component of resources, and the aspect of training of personnel. |
| 05000338/FIN-2012004-03 | 2012Q4 | North Anna | Licensee-Identified Violation | Technical Specification 5.4.1.a states, in part, that written procedures shall be implemented covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, of which Section 9 specifies procedures for performing maintenance. Contrary to this, on August 27, 2012, the licensee identified that on August 18, 2012 maintenance personnel failed to verify that an adequate amount of oil was added to the Unit 1 A charging pump speed increaser gearbox following maintenance activities, as required by licensee procedure 0-MPM-0103-01, Preventative Maintenance of Charging/High-Head Safety Injection Pumps, Revision 26. This issue is more than minor because it adversely affected the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and the related attribute of human performance. Specifically, the Unit 1 A charging pump was degraded because additional oil needed to be added to ensure that the charging pump could fulfill its safety-related function. The inspectors determined that this finding was of very low safety significance (Green) because the finding did not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time or two separate safety systems out-of-service for greater than its technical specification allowed outage time. The inspectors determined that the licensee correctly evaluated the finding and developed appropriate corrective action as documented in the licensees CAP as CR486077. |
| 05000338/FIN-2012003-01 | 2012Q2 | North Anna | Failure to identify PWSCC in the Unit 1 B SG hot leg safe-end weld | A self revealing non-cited violation (NCV) of the required augmented ISI examinations identified in 10 CFR 50.55a(g)(6)(ii)(F), Examination requirements for Class 1 piping and nozzle dissimilar metal butt welds, which implements ASME Code Case N-770-01, that covers alternative examination requirements and acceptance standards for Class 1 PWR Piping and Vessel Butt Welds Fabricated with Alloy 82 and 182 Filler Material was identified for the licensees failure to identify unacceptable PWSCC indications in the Unit 1 B SG hot leg nozzle safe-end weld. These requirements require in-service examinations to be performed using qualified techniques and with qualified personnel capable to identify primary water stress corrosion cracking (PWSCC) indications. The licensee entered this issue into its corrective action program as condition report CR467649. The inspectors determined that the failure to identify the PWSCC indications in the Unit 1 B steam generator (SG) hot leg safe-end weld was a self-revealing performance deficiency that was within the licensees ability to foresee and correct. Using IMC 0612, the inspectors determined that this finding was of more than minor significance because the failure to identify the PWSCC could have resulted in the potential to allow degradation of the safe-end to proceed undetected. Unchecked PWSCC degradation could have resulted in more significant degradation of the safeend weld with subsequent degradation of the primary system pressure boundary. The finding is associated with the design control attribute of the Barrier Integrity Cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, examinations of the SG safe-end welds provide assurance that the structural boundary of the reactor coolant system remains capable of performing its intended safety function. The inspectors used IMC 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, and determined that the finding was of low safety significance (Green) because it did not represent an actual failure of the safe-end pressure retaining boundary. The inspectors identified a cross-cutting aspect in the Human Performance Work Practices cross cutting area, H.4 (c). Specifically, the licensee failed to conduct an adequate briefing with NDE technicians prior to the examination to ensure its successful execution. |
| 05000338/FIN-2012003-02 | 2012Q2 | North Anna | Examination of SG safe-end weld with possible unqualified ultrasonic examination procedures | The licensee qualified the manual UT procedure in accordance with the EPRI Performance Demonstration Initiative (PDI) process utilizing the PDI procedure IR- 2009-358, for site specific qualification. This process allows for qualification that utilizes a site specific mock-up in an open demonstration process. Although this qualification is used by the industry in meeting the requirements of Appendix VIII of Section XI, there are concerns with the inconsistency with respect to the application of robust, blind demonstration approaches versus less rigorous, and open qualifications. This issue was highlighted as a result of the missed indications at North Anna. The licensee requested that EPRI review (TJ) IR-2009-358 to reassess the current validity of the information provided within this document. With respect to the open demonstration process, EPRI has determined the stated position (of using an open demonstration process) in (TJ) IR- 2009-358 to continue to be acceptable, which is inconsistent with their approach to the use of Code Case N-770, where EPRI requires that a blind demonstration test be passed. This inconsistency needs to be further discussed and a path forward defined in order to develop guidance for application during either type of performance demonstration. In addition, the inspectors and members of the NRR staff conducted on-site evaluations of the site specific UT procedure and inspection technique. This evaluation was conducted on the site specific calibration blocks and with the same UT probes that the licensee used to qualify the UT procedure and the qualification of the NDE technicians. Subsequently, the NRC staff requested Pacific Northwest National Laboratory (PNNL) to evaluate the qualification of the manual UT procedure that was used to examine the safe-end weld. The results were presented in PNNL Report PNNL-21546, Evaluation of Manual Ultrasonic Examinations Applied to Detect Flaws in Primary System Dissimilar Metal Welds at North Anna Power Station, (ML12200A216). This report determined that the site specific approach for the manual UT technique does not meet the intent of the requirements of Appendix VIII of ASME Section XI. Also identified was that the probes used to conduct the site examinations did not meet the procedure requirements of licensee procedure ER-AA-NDE-180 for UT probe angles. This issue remains unresolved until questions associated with the qualification of the UT procedure, including that the probes that did not meet the procedural requirements for UT probe angles and the adequacy of the site specific mock-ups are resolved. This issue is identified as URI 05000338/2012003-02, Examination of SG safe-end weld with possible unqualified ultrasonic examination procedures. |
| 05000338/FIN-2012002-01 | 2012Q1 | North Anna | Failure to Provide Required Power for the Seismic Instrumentation Annunciators | An NRC-identified, Green, finding (FIN) was identified by the inspectors for the licensees failure to provide continuous standby power and sufficient power for a minimum 25 minutes of system operation for seismic instruments as required by a licensee self-imposed standard documented in the licensees Updated Final Safety Analysis Report (UFSAR) which resulted in required seismic alarms and indications not being received in the main control room. Specifically, the licensee failed to provide the required power for both a triaxial response-spectrum recorder capable of providing signals for immediate control room indication and for the control room annunciator for the seismic switch. The licensee entered this issue into their corrective action program as CR468442. Immediately following the August 23, 2011 seismic event the licensee completed a temporary modification to connect an uninterruptible power supply to the seismic monitoring panel. In addition, the licensee is executing a design change to upgrade the site seismic monitoring equipment. The inspectors reviewed IMC 0612, Appendix B and determined that the performance deficiency was more than minor because it adversely impacted the Design Control attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors reviewed IMC0609, Attachment 4 and determined that the finding was of very low safety significance, Green, because it did not screen as potentially risk significant using the seismic screening criteria contained in Attachment 4. The cause of this finding did not involve a cross-cutting aspect as it is not indicative of current licensee performance. |
| 05000338/FIN-2012002-02 | 2012Q1 | North Anna | Licensee-Identified Violation | TS 5.7.2 requires, that each High Radiation Area (HRA) with dose rates greater than 1.0 rem/hour at 30 centimeters shall be provided with a locked or continuously guarded door or gate that prevents unauthorized entry and that access to, and activities in, each such area shall be controlled by means of an RWP. Contrary to the above, on August 14, 2011, a security officer performing verification of equipment status for a security alarm test outside the U1 personnel hatch inadvertently entered a posted Locked High Radiation Area (LHRA) under an incorrect Radiation Work Permit (RWP). An HP technician entered the LHRA to perform a pre-job survey in preparation for the alarm testing and was out of visual control of the LHRA door. After performing the survey, the HP technician discovered the officer had inadvertently crossed the LHRA boundary and escorted him out. Immediate corrective actions were taken upon discovery and documented in CR437863. The violation was evaluated using the Occupational Radiation Safety Significance Determination Process and was determined to be of very low safety significance (Green) because this finding did not involve ALARA planning or work controls, was not an over-exposure, did not have a substantial potential for overexposure, and the ability to access dose was not compromised. |
| 05000338/FIN-2011011-01 | 2011Q4 | North Anna | Seismic Instrumentation Implementation | The team reviewed records and interviewed personnel to determine whether the seismic instruments at the North Anna Power Station were maintained and calibrated properly to provide accurate information for making decisions on safe shutdown during and following a seismic event and for subsequent engineering analysis. The team completed this task by reviewing seismic instrument manuals, and other related documents, and a sample of calibration documents. The team also interviewed licensee engineers and inspected instrument scratch plates that recorded the initial seismic activity. The team found that two potential generic issues exist related to the seismic instrumentation system and implementation. These issues and one related URI are described in this section. A second related URI is described in Section 7.5. The team conducted walk-downs of all seismic instruments located in Unit 1 Containment and Auxiliary Buildings. During the walk-downs, the team visually inspected all of the seismic instruments at various levels of elevation of the two buildings. The installation of seismic equipment appeared consistent with the equipment vendor manuals. The licensees records indicated that seismic equipment, including both Engdahl and Kinemetrics, was checked every 18 months during refueling outages. Through review of records and interviews with licensee personnel, the team noted the following issues with seismic instruments: 1. All the seismic instrumentation was located on plant structures, and no seismometers were installed on a free surface in the free field; therefore, the team questioned whether the instrumentation would provide a reliable indicator for determining whether an earthquake had exceeded Operating Basis Earthquake (OBE) or Safe Shutdown Earthquake (SSE) ground motion levels. 2. A seismic alarming system panel lost power during the event and it was not connected to an uninterruptible electric power supply. In addition, some other equipment issues were observed during the event follow-up. The team questioned whether the seismic equipment and associated alarming systems were adequate to perform their expected function considering the equipment issues observed during the event. Because these two issues may be applicable to other operating nuclear power plants, the team determined that they represented potential generic issues. Specific issues with the equipment included: A seismic alarming system panel lost power during the event and it was not connected to an uninterruptible electric power supply. The team questioned whether the seismic equipment and associated alarming systems were adequate to perform their expected function considering equipment issues observed during the event. Seismic recordings were inconsistent between the Kinemetrics and Engdahl scratch plates located on the base-mat of Unit 1. Some of the Engdahl scratch plates did not record any ground motion. Both orientations of Kinemetrics and Engdahl scratch plate equipment located at different elevation levels were misidentified; therefore, the data for East-West and North-South was initially swapped. A deficiency was previously identified by the licensee on the seismic alarming system, affecting one of the panels alarms, but remained pending repair (Work Order 59102235553 and Condition Report (CR) 403883). Instrument Panel OBE and SSE values were not consistent with FSAR 3.7.4 (OBE exceedance) and the licensees system training manual (Module NCRODP-72-NA: amber light indicates 67 percent of DBE for frequency of a particular reed in either the L, T or V direction; red light indicates 100% DBE for the frequency of a particular reed in either the L,T or V direction). The licensee entered this issue into their corrective action program as CR 442880. Based on the review of maintenance and calibration records, the team did not find documentation indicating performance of cross-checks and calibration of different types of seismic equipment against each other to ensure the signals recorded were consistent with regard to frequency and amplitudes. Seismic recordings were not clocked or referenced to the plants event recorders; therefore, the start time of seismic activity time history recordings required estimation. The team determined that the issues with seismic instrument implementation warranted additional NRC review and follow-up considering that information from this system served as an input into event response decision making. Additional review by the NRC will be needed to determine whether any of the issues represents a performance deficiency. An unresolved item will be opened pending completion of this review. The issue will be identified as URI 05000338, 339/2011011-01, Seismic Instrumentation Implementation. |
| 05000338/FIN-2011011-04 | 2011Q4 | North Anna | 1J EDG Frequency Oscillation | Following the seismic event on August 23, 2011, while the 1J EDG was supplying power to the 1J emergency bus, control room operators identified frequency oscillations on the 1J EDG bus as well as 1-III and 1-IV inverter momentary trouble alarms when the pressurizer heaters were cycled. During personnel interviews, bus frequency was reported as oscillating between 59 and 61Hz. The inspectors noted a Technical Specification Limit of 59.5 and 60.5Hz. Engine load cycled between 1600 and 2000KW while the 1J EDG was supplying power to the bus, varying as pressurizer heater loads cycled. The PCS did not have a data point for emergency bus frequency so actual emergency bus frequency was not recorded and could not be conclusively obtained. The licensee entered this issue into the corrective action program as CR 440231. There was a PCS data point that indicated engine speed (rpm), which could have been used to calculate frequency with quality data available; however this PCS point for the 1J EDG was very noisy during the event and could not provide any useful data to determine the magnitude of frequency oscillations. All four EDG speed points on the PCS were trended using engine run data since the seismic event occurred. Each engine was operating parallel to the grid (stable at 900rpm) to observe stability of the data point. There was noise in each data point: 1H, 2H and 2J showed oscillations of 20-30rpm when paralleled and had a nominal speed indication between 895 and 920rpm. The 1J data point showed oscillations of 100rpm in isochronous mode and when paralleled to the grid and could therefore not be used to conclusively determine the 1J emergency bus frequency. This data point was used for indication only and was not related to actual engine stability. On September 5, the licensee conducted a PMT of the 1J EDG in manual mode. During that run, a troubleshooting sheet was prepared in response to CR 440231 and qualified test equipment was used to measure engine frequency/voltage, electronic governor null voltage, and the PCS rpm data point. Frequency responded as expected when control was switched from the mechanical governor to the electric governor actuator and was measured stable at 60.2Hz. The licensee was not able to test the 1J EDG in isochronous mode, which was the configuration during the event due to current plant conditions; however, the licensee was scheduled to recreate the scenario during the upcoming refueling outage. The engine RPM indication is a separate issue that may also be addressed during this evolution. An unresolved item will be opened pending completion and results of licensee testing. This issue will be identified as URI 05000338, 339/2011011-04, 1J EDG Frequency Oscillations. |