IR 05000338/2012004

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IR 05000338-12-004, 05000339-12-004 North Anna Power Station, Units 1 and 2, Routine Integrated Inspection Report. Adverse Weather Protection, Identification and Resolution of Problems
ML12310A309
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 11/05/2012
From: Gerald Mccoy
NRC/RGN-II/DRP/RPB5
To: Heacock D
Virginia Electric & Power Co (VEPCO)
References
IR-12-004
Download: ML12310A309 (31)
v • d • e


Text

UNITED STATES mber 5, 2012

SUBJECT:

NORTH ANNA POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000338/2012004, 05000339/2012004

Dear Mr. Heacock:

On September 30, 2012, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your North Anna Power Station Units 1 and 2. The enclosed integrated inspection report documents the inspection findings which were discussed on October 23, 2012, with Mr.

G. Bischof and other members of your staff.

The inspection examined activities conducted under your licenses as they related to safety and compliance with the Commissions rules and regulations and with the conditions of your licenses. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents one NRC-identified finding and one self-revealing finding of very low safety significance (Green) which were identified during this inspection. One of these findings involved violation of NRC requirements. Additionally, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. The NRC is treating these as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you wish to contest these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the North Anna Power Station.

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 Regional Administrator, Region II, and the NRC Resident Inspector at the North Anna Power Station. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects

Enclosure:

Inspection Report 05000338/2012004, 05000339/2012004 w/ Attachment: Supplemental Information

REGION II==

Docket Nos: 50-338, 50-339 License Nos: NPF-4, NPF-7 Report No: 05000338/2012004, 05000339/2012004 Licensee: Virginia Electric and Power Company (VEPCO)

Facility: North Anna Power Station, Units 1 & 2 Location: 1022 Haley Drive Mineral, Virginia 23117 Dates: July 1, 2012 through September 30, 2012 Inspectors: G. Kolcum, Senior Resident Inspector R. Clagg, Resident Inspector D. Berkshire, Emergency Preparedness Inspector (4OA2.2)

Accompanied by: M. Levine, Nuclear Safety Professional Development Program (Training)

A. Toth, Operations Engineer (Training)

Approved by: Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000338/2012-004, 05000339/2012-004 North Anna Power Station, Units 1 and 2, Routine

Integrated Inspection Report. Adverse Weather Protection, Identification and Resolution of Problems.

The report covered a 3 month period of inspection by resident inspectors and reactor inspectors from the region. Two findings were identified of which one was determined to be a non-cited violation (NCV). The significance of most findings is indicated by their color (Green, White,

Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). The cross-cutting aspect was determined using IMC 0310, Components Within the Cross Cutting Areas. Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

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 safety-related 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. (Section 1R01.2)

Cornerstone: Emergency Preparedness

  • Green: 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

H.2(b). (Section 4OA2.2)

Licensee Identified Violations

A violation of very low safety significance, which was identified by the licensee, was reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and its respective corrective actions are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the period at full Rated Thermal Power (RTP) and operated at full power for the entire report period.

Unit 2 began the inspection period at full RTP and operated at full power for the entire report period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

==1R01 Adverse Weather Protection

.1 Site Specific Event

a. Inspection Scope

==

The inspectors performed the three site specific weather related inspections listed below due to anticipated adverse weather conditions in the area. Specifically, the inspectors reviewed licensee adverse weather response procedures and site preparations including work activities that could impact the overall maintenance risk assessments.

  • Severe thunderstorms warning expected to bring heavy winds and rain on July 24, 2012
  • Severe thunderstorms and heavy winds expected in the area on August 15, 2012
  • Severe thunderstorms on September 18, 2012 with a tornado watch issued for area

b. Findings

No findings were identified.

.2 Operating Experience (OpEss) High Wind Generated Missile Hazards

a. Inspection Scope

The inspectors performed walkdowns of the three areas listed below to assess the licensee vulnerability to tornado induced missiles and loose or unsecured materials for outside structures and equipment. As part of this assessment, the inspectors:

(1) made sure power supplies, high pressure cylinders, and such, are protected from potential missiles;
(2) reviewed the use of procedures during adverse weather events; (3)reviewed translation of regulatory requirements and design basis information to specs, drawings, and such, for impact on safety related equipment;
(4) ensured all normally open tornado doors can be shut in a timely manner; and,
(5) reviewed calculations for tornado wind loadings and missile generation for safety related equipment, cranes, fuel transfer casks, condensate storage tank piping, and protective enclosures.
  • Independent Spent Fuel Storage Installation (ISFSI)

Documents utilized and reviewed as part of the inspections are listed in the Attachment to this report.

b. Findings

Introduction:

The NRC identified a Green, NCV of 10 CFR 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).

Description:

The inspectors identified an issue of concern involving the lack of tornado missile protection for a pipe penetration from the diesel-driven fire pump fuel-oil day tank vent lines through the SWPH wall. The inspectors determined that an introduction of a design-basis missile through this penetration could adversely impact a motor-control cabinet (MCC) interior to the SWPH that provides power to safety related SWPH ventilation system loads. The inspectors reviewed UFSAR Table 3.2-1, Structures Systems, and Components that are Designed to Seismic and Tornado Criteria, and noted that the SWPH ventilation system has a P designation, which refers to systems and components that will not fail during a design-basis tornado, since they are protected by tornado-resistant structures. In addition, the inspectors reviewed calculation CE-1934, which analyzed the penetration depth, through steel, of the design-basis tornado-generated missiles. The inspectors questioned the adequacy of the tornado missile protection of the pipe penetration into the SWPH. Specifically, the pipe and the void around the pipe penetration in the SWPH structure may be susceptible to perforation by a design-basis missile, as shown in calculation CE-1934.

The licensee initiated condition report (CR) 479566, SWPH Tornado Missile Protection Vulnerability, and determined that, the missile protective function of the SWPH at this discrete location is not capable of performing its design function and requires modification and/or compensatory action. The licensee installed a temporary missile shield and initiated design change NA-12-00056 to implement the long-term corrective action. The inspectors reviewed the CR and the licensees corrective action program (CAP), along with associated extent of condition evaluations for previously identified tornado missile protection deficiencies.

The licensee implements their CAP through procedure PI-AA-200, Revision 20, Corrective Action." Step 1.1 of the procedure states, This procedure establishes the process for identifying and documenting operability and reportability of conditions potentially adverse to quality. Step 5.2.8 states, Engineering is responsible for providing technical justification to support operability decisions in accordance with OP-AA-102, Operability Determination. Procedure OP-AA-102, Revision 8, "Operability Determination," states in step 3.2.6d, "the following items are required to be evaluated and documentedthe extent of condition for all similarly affected Technical Specifications (TS) systems, structures and components. Procedure PI-AA-200, in step 5.3.21, defines extent of condition as, the extent to which the actual condition exists (or may exist) with other plant equipment, organizations, processes, or human performance.

The inspectors reviewed the following CRs with their associated operability determinations (OD) and corrective actions, to determine if the extent of condition evaluations and reviews, required by the licensees CAP, were adequate to identify and correct conditions adverse to quality:

  • CR001132, dated September 8, 2006, reported a concern the NRC Senior Resident had regarding missile protection on the turbine-driven auxiliary feedwater (TDAFW)pump. The resulting OD, OD000019, addressed the operability of the TDAFW pump in light of the identified missile vulnerability. In the extent of condition section of the OD, the licensee also listed the diesel-driven fire pump exhaust and fuel-oil tank vent pipes, which penetrate the SWPH, as potentially vulnerable to a tornado driven missile. The licensee last reviewed OD000019 on March 31, 2009 and closed the OD on April 22, 2009, following the completion of modifications to implement tornado missile protection for TDAFW pump steam exhaust piping.
  • CR008613, dated March 13, 2007, identified components of the diesel-driven fire pump that were listed in OD000019 as lacking tornado missile protection. The resulting OD, OD000081, addressed the operability of the diesel-driven fire pump in light of the identified missile vulnerabilities. In the extent of condition section of OD000081, the licensee determined that the pumps exhaust pipe and fuel-oil tank vent pipe were not missile protected and that, "the extent of this Operability Determination is limited to these two identified items. The licensee last reviewed OD000081 on January 13, 2010. The licensee closed the OD on November 4, 2009, following the completion of a design change (DC) to implement tornado missile protection for diesel-driven fire pump fuel oil tank vent piping. The DC however addressed the possibility of a tornado-generated missile pushing the vent line back into the SWPH upon impact, not the potential introduction of a missile through the pipe penetration and the effects on the service water system as a result.
  • CR335365, dated May 19, 2009, reported a concern the NRC Senior Resident had regarding missile protection on the emergency diesel generator (EDG) fuel-oil day tank vent and overflow lines. The resulting OD, OD000297, addressed the operability of the EDG turbine driven pump in light of the identified missile vulnerability. In response to the OD, the licensee implemented DC NA-11-01031, EDG Day Tank Missile Protection Modification, dated January 18, 2012. In the DC, the licensee stated that the vent and overflow line penetrations were susceptible to tornado-missile penetration and that, according to CE-1934, a 2 thick steel plate was required to prevent perforation by a design basis missile. In the latest review of OD000297 on April 11, 2012, the licensee determined that, there are currently no other OD or RAS that have any applicability to OD000297. Consequently, the extent of condition section of OD000297 continued to indicate that the identified condition was applicable to just the EDG fuel-oil day tanks. The OD remains open pending completion of NA-11-01031.

The inspectors concluded that the licensees CAP and the required extent of condition evaluations did not adequately identify and correct conditions adverse to quality. The inspectors identified that the licensee failed to identify and correct a condition adverse to quality involving inadequate missile protection for a pipe penetration into the SWPH despite multiple extent of condition evaluations surrounding inadequate missile protection of piping. This finding was identified in connection with a review of Operating Experience Smart Smaple OpESS 2012/01-01, High Wind Generated Missile Hazards.

Analysis:

The inspectors reviewed the issue of concern in accordance with Inspection Manual Chapter (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 impact one train of the safety-related SWPH ventilation system due to an inadequate tornado missile protection for pipe penetrations.

The inspectors evaluated the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) 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-TS Trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 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.

Enforcement:

10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," states in part that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to the above, from September 11, 2006 to June 21, 2012 the licensee failed to promptly identify and correct a condition adverse to quality involving inadequate tornado missile protection for a pipe penetration into the SWPH. Because the finding is of very low safety significance and it was entered into the licensees CAP as CR479566, this violation is being treated as a Green NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000338, 339/2012004-01, Failure to Promptly Identify and Correct a Condition Adverse to Quality Involving Inadequate Tornado Missile Protection for a Pipe Penetration in the SWPH.

==1R04 Equipment Alignment

.1 Partial Walkdowns

a. Inspection Scope

==

The inspectors conducted three equipment alignment partial walkdowns to evaluate the operability of selected redundant trains or backup systems, listed below, with the other train or system inoperable or out of service. The inspectors reviewed the functional systems descriptions, UFSAR, system operating procedures, and TS to determine correct system lineups for the current plant conditions. The inspectors performed walkdowns of the systems to verify that critical components were properly aligned and to identify any discrepancies which could affect operability of the redundant train or backup system.

  • Unit 1 B and C charging pump trains during extended maintenance on A charging pump
  • Unit 1 casing cooling system during Unit 1 casing cooling tank level instrument failure
  • Unit 2 casing cooling system during Unit 1 casing cooling tank level instrument failure

b. Findings

No findings were identified.

.2 Complete Walkdown

a. Inspection Scope

The inspectors performed a detailed walkdown and inspection of the Unit 2 service water system to assess proper alignment and to identify discrepancies that could impact its availability and functional capacity. The inspectors assessed the physical condition and position of each valve, whether manual, power operated, or automatic, to ensure correct positioning of the valves. The inspection also included a review of the alignment and the condition of support systems including fire protection, room ventilation, and emergency lighting. Equipment deficiency tags were reviewed and the condition of the system was discussed with the engineering personnel. The operating procedures, drawings, and other documents utilized and reviewed as part of the inspection are listed in the to this report.

b. Findings

No findings were identified.

==1R05 Fire Protection

.1 Fire Protection - Tours

a. Inspection Scope

==

The inspectors conducted focused tours of the five areas listed below that are important to reactor safety to verify the licensees implementation of fire protection requirements as described in fleet procedures CM-AA-FPA-100, Fire Protection/Appendix R (Fire Safe Shutdown) Program, Revision 5, CM-AA-FPA-101, Control of Combustible and Flammable Materials, Revision 4, and CM-AA-FPA-102, Fire Protection and Fire Safe Shutdown Review and Preparation Process and Design Change Process, Revision 3.

The inspectors evaluated, as appropriate, conditions related to:

(1) licensee control of transient combustibles and ignition sources;
(2) the material condition, operational status, and operational lineup of fire protection systems, equipment, and features; and,
(3) the fire barriers used to prevent fire damage or fire propagation.

TDAFW-2), Motor-Driven Auxiliary Feedwater Pump Room Unit 1 (fire zone 14B-1a /

MDAFW-1), and Motor-Driven Auxiliary Feedwater Pump Room Unit 2 (fire zone 14B-2a / MDAFW-2)

  • Main and Station Service Transformers (fire zone Z-8C / XFMRS), Security Auxiliary Power Supply Building (fire zone Z-39 / APSB), and Alternate AC Building (fire zone Z-52 / AAC)
  • Main Steam Valve House Unit 2 (includes MG Set Room) (fire zone 17-2a / MSVH-1-1)
  • Charging Pump Cubicle 1-1A (fire zone 11Aa / CPC-1A0, Charging Pump Cubicle 1-1B (fire zone 11Ba / CPC-1B), Charging Pump Cubicle 1-1C (fire zone 11Ca /

CPC-1C), Charging Pump Cubicle 2-1A (fire zone 11Da / CPC-2A), Charging Pump Cubicle 2-1B (fire zone 11Ea / CPC-2B), Charging Pump Cubicle 2-1C (fire zone 11Fa / CPC-2C)

Documents utilized and reviewed as part of these inspections are listed in the to this report.

b. Findings

No findings were identified.

.2 Fire Protection - Drill Observation

a. Inspection Scope

During a fire protection drill on September 11, 2012, at the Unit 1 Turbine Building basement which involved a lube oil fire in the turbine oil conditioner, the inspectors assessed the timeliness of the fire brigade in arriving at the scene, the fire fighting equipment brought to the scene, the donning of fire protection clothing, the effectiveness of communications, and the exercise of command and control by the scene leader. The inspectors also assessed the acceptance criteria for the drill objectives and reviewed the licensees corrective action program for recent fire protection issues.

b. Findings

No findings were identified.

==1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review

==

a. Inspection Scope

The inspectors reviewed licensed operator requalification scenario SEG7E on July 6, 2012, which involved a ramp-down from 15% power to ~7% power, a fire in Unit 2 B main transformer, loss of C reserve station service transformer, and a loss of 1H emergency bus, resulting in a Notice of Unusual Event (NOUE) emergency notification.

The scenario required classifications and notifications that were counted for NRC performance indicator input.

The inspectors observed crew performance in terms of communications; ability to take timely and proper actions; prioritizing, interpreting, and verifying alarms; correct use and implementation of procedures, including the alarm response procedures; timely control board operation and manipulation, including high-risk operator actions; and oversight and direction provided by the shift supervisor, including the ability to identify and implement appropriate TS actions. The inspectors observed the post training critique to determine that weaknesses or improvement areas revealed by the training were captured by the instructor and reviewed with the operators.

b. Findings

No findings were identified.

.2 Operator Observations

a. Inspection Scope

During the inspection period, the inspectors conducted observations of licensed reactor operators actions and activities to ensure that the activities were consistent with the licensee procedures and regulatory requirements. These observations took place during both normal and off-normal plant working hours. As part of this assessment, the inspectors observed the following elements of operator performance:

(1) operator compliance and use of plant procedures including technical specifications;
(2) control board/in-plant component manipulations;
(3) use and interpretation of plant instruments, indicators and alarms;
(4) documentation of activities;
(5) management and supervision of activities; and,
(6) communication between crew members.

The inspectors observed and assessed licensed operator performance during the following events;

  • During an EDG fuel oil storage tank alarm on July 2, 2012
  • In response to a rod deviation alarm for control rod B-6 individual rod position indication on July 13, 2012
  • In response to a 2H EDG trouble alarm for low starting air pressure on July 31, 2012
  • In response to a 1J EDG alarm module failure on September 6, 2012

b. Findings

No findings were identified.

==1R12 Maintenance Effectiveness

a. Inspection Scope

==

For the two equipment issues listed below, the inspectors evaluated the effectiveness of the respective licensee's preventive and corrective maintenance. The inspectors performed walkdowns of the accessible portions of the systems, performed in-office reviews of procedures and evaluations, and held discussions with licensee staff. The inspectors compared the licensees actions with the requirements of the Maintenance Rule (10 CFR 50.65), and licensee procedure ER-AA-MRL-10, Maintenance Rule Program, Revision 4.

  • Maintenance Rule Evaluation (MRE) 015420, MRE to Engineering for SW MIC leak was observed on 2-WS-C84-153A-Q3
  • MRE 015466, MRule evaluation to Eng for 1-QS-MOV-101B failed to stroke closed

b. Findings

No findings were identified.

==1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

==

The inspectors evaluated, as appropriate, the four activities listed below for the following:

(1) effectiveness of the risk assessments performed before maintenance activities were conducted;
(2) management of risk;
(3) upon identification of an unforeseen situation, necessary steps were taken to plan and control the resulting emergent work activities; and,
(4) maintenance risk assessments and emergent work problems were adequately identified and resolved. The inspectors verified that the licensee was in compliance with the requirements of 10 CFR 50.65 (a)(4) and the data output from the licensees safety monitor associated with the risk profile of Units 1 and 2. Documents reviewed are listed in the Attachment to this report.
  • Emergent work on 2-CH-P-1C due to a service water pipe leak on July 17, 2012
  • Updated maintenance risk assessment during severe thunderstorms on July 24, 2012
  • Updated maintenance risk assessment during severe thunderstorms and heavy winds on August 15, 2012
  • Updated maintenance risk assessment of Unit 1 charging pump 1B with oil level in speed changer out of sight high on September 7, 2012

b. Findings

No findings were identified.

==1R15 Operability Determinations and Functionality Assessments

=

.1 Site Operability Determinations and Functionality Assessments===

a. Inspection Scope

The inspectors reviewed eight operability determinations and functionality assessments, listed below, affecting risk-significant mitigating systems, to assess, as appropriate: (1)the technical adequacy of the evaluations;

(2) whether continued system operability was warranted;
(3) whether other existing degraded conditions were considered as compensating measures;
(4) whether the compensatory measures, if involved, were in place, would work as intended, and were appropriately controlled; and,
(5) where continued operability was considered unjustified, the impact on TS Limiting Conditions for Operation and the risk significance in accordance with the SDP. The inspectors review included a verification that ODs were made as specified by procedure OP-AA-102, Operability Determination, Revision 6. Other documents reviewed are listed in the to this report.
  • OD000484, "Complete prompt OD on SW System"
  • OD000487, Complete OD evaluation 1-CH-MPV-1115B motor thermal overload tripping early
  • OD000488, Body to bonnet leak found on 2-BD-TV-200B
  • OD000489, Validate the reasonable expectation for operability provided in CR479690
  • CR481698, 2-EE-EG-2H coolant leakage rate into waste coolant tank is increasing
  • OD000179, Address effect of oil leak and resulting fire on EDG operability
  • CR486678, Unit 1 charging pump 1B oil level in speed changer above target sight glass
  • CR486673, Unit 1 charging pump 1A oil level low in speed changer

b. Findings

No findings were identified.

.2 Operating Experience (OpEss) Technical Specification Interpretation and Operability

Determination

a. Inspection Scope

The inspectors reviewed CR428450, "Service water pump house missile vulnerability,"

to evaluate the licensees assessment of system operation following the implementation of compensatory measures which substituted manual operator action for automatic action to perform a specified safety function.

The inspectors also reviewed IOD000175, "Quench Spray and Outside Service Spray Pump Discharge Check Valve Testing," to ensure the licensee entered all required actions immediately, based on plant conditions, regardless of whether or not the periodicity of the TS surveillance interval had expired. The inspectors reviewed the applicable licensee procedure requirements for a surveillance not performed within its specified frequency to ensure they were properly implemented and that all applicable TS requirements were identified and implemented within the allowed TS completion time.

As part of these assessments, the inspectors:

(1) made sure the measures put in place would work as intended;
(2) did not cause system operation to be outside the design basis;
(3) were appropriately controlled;
(4) did not result in changes to tests or experiments described in UFSAR; and,
(5) if the changes to tests and experiments were different than what was described in the UFSAR, verified that the changes or experiments met the various criteria specified in 10 CFR 50.59 for not requiring a license amendment.

b. Findings

No findings were identified.

==1R19 Post Maintenance Testing

a. Inspection Scope

==

The inspectors reviewed seven post maintenance test procedures and/or test activities for selected risk-significant mitigating systems listed below, to assess whether:

(1) the effect of testing on the plant had been adequately addressed by control room and/or engineering personnel;
(2) testing was adequate for the maintenance performed; (3)acceptance criteria were clear and adequately demonstrated operational readiness consistent with design and licensing basis documents;
(4) test instrumentation had current calibrations, range, and accuracy consistent with the application;
(5) tests were performed as written with applicable prerequisites satisfied;
(6) jumpers installed or leads lifted were properly controlled;
(7) test equipment was removed following testing; and,
(8) equipment was returned to the status required to perform in accordance with VPAP-2003, Post Maintenance Testing Program, Revision 14. Other documents reviewed are listed in the Attachment to this report.

b. Findings

No findings were identified.

==1R22 Surveillance Testing

a. Inspection Scope

==

For the four surveillance tests listed below, the inspectors examined the test procedures, witnessed testing, or reviewed test records and data packages, to determine whether the scope of testing adequately demonstrated that the affected equipment was functional and operable, and that the surveillance requirements of TS were met. The inspectors also determined whether the testing effectively demonstrated that the systems or components were operationally ready and capable of performing their intended safety functions. Documents reviewed are listed in the Attachment to this report.

In-Service Test:

  • 1-PT-71.3Q.1, 1-FW-P-3B, B Motor-Driven AFW IST Comprehensive Pump and Valve Testing, Revision 10 Other Surveillance Tests:
  • 0-PT-82.11, Quarterly Test of 0-AAC-DG-OM, Alternate AC Diesel Generator (SBO Diesel), on D transfer Bus, Revision 24

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

.1 Simulator Drill

a. Inspection Scope

On August 21, 2012, the inspectors reviewed and observed the performance of an simulator drill that involved simulated fuel damage, a loss of 1H emergency bus, a steam generator tube rupture and a main steam safety valve that was stuck open. The inspectors assessed emergency procedure usage, emergency plan classification, notifications, and the licensees identification and entrance of any problems into their corrective action program. This inspection evaluated the adequacy of the licensees conduct of the drill and critique performance. Exercise issues were captured by the licensee in their CAP as CR485615. Requalification training deficiencies were captured within the operator training program.

b. Findings

No findings were identified.

.2 Emergency Planning Drill

a. Inspection Scope

The inspectors reviewed the biennial 2012 emergency response exercise for North Anna as required by Section IV.F.2.c of Appendix E to 10 CFR Part 50. The review assessed whether the licensee created a scenario suitable to test the major emergency plan elements in accordance with Appendix E to 10 CFR Part 50. The adequacy of the licensees performance in the biennial exercise was reviewed and assessed with regard to the implementation of the Risk Significant Planning Standards in 10 CFR 50.47 (b)(4),

(5), (9), and

(10) which address emergency classification, offsite notification, radiological assessment and protective action recommendations.

Licensee activities inspected during the exercise included independent observations in the Control Room Simulator, Local Emergency Operations Facility, Technical Support Center, and Operations Support Center. The exercise was conducted on July 10, 2012.

The inspectors reviewed a sample of corrective actions, and determined whether performance trends represented a failure to: correct weaknesses, meet planning standards or meet other regulatory requirements. The inspectors evaluated command and control, the transfer of emergency responsibilities between facilities, communications, adherence to procedures, and the overall implementation of the emergency plan. The inspectors attended the post-exercise critique to evaluate:

(1) the licensees self-assessment process, and,
(2) the presentation of critique results to plant management.

At the conclusion of these evaluations and independent observations, the inspectors determined the exercise was a satisfactory test of the Emergency Plan and the licensees response to the simulated emergency conditions met the requirements of 10 CFR 50.47(b).

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

The inspectors performed a periodic review of the following five Unit 1 and 2 PIs to assess the accuracy and completeness of the submitted data and whether the performance indicators were calculated in accordance with the guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspection was conducted in accordance with NRC inspection procedure 71151, Performance Indicator Verification. Specifically, the inspectors reviewed the Unit 1 and Unit 2 data reported to the NRC for the period July 1, 2011 through June 30, 2012.

Documents reviewed included applicable NRC inspection reports, licensee event reports, operator logs, station performance indicators, and related CRs.

  • Emergency AC Power System (MS06)
  • High Pressure Injection System (MS07)
  • Heat Removal Systems (MS08)
  • Support Cooling Water Systems (MS10)

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Review of Items Entered into the Corrective Action Program

As required by NRC inspection procedure 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished by reviewing daily CR report summaries and periodically attending daily CR Review Team meetings.

.2 Annual Sample: Review of CR439343, Challenges to Personnel Accountability

Following Declared Alert

a. Inspection Scope

The inspectors reviewed the licensees evaluation and corrective actions for CR 439343, Challenges to Personnel Accountability Following Declared Alert, to ensure that the full extent of the issue was identified, an appropriate evaluation was performed, and adequate corrective actions were specified and prioritized. The inspectors also evaluated the CR against the requirements of the licensees corrective action program as specified in procedure, PI-AA-200, Corrective Action.

b. Findings and Observations

Introduction:

The inspectors identified a Green finding for the licensees failure to follow posted manual personnel accountability instructions which resulted in delays in completing the accounting process. 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.

Description:

The licensee declared an Alert emergency classification at 2:03 p.m.

following an earthquake at 1:51 p.m. on August 23, 2011. 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. EPIP 5.03 instructed Security personnel to maintain continuous protected area accountability until event termination. As required by the North Anna Emergency Plan, site assembly was conducted and emergency response facilities were staffed. An announcement was made for all personnel to report to their designated Emergency Assembly Areas for accountability. Due to the event, the accountability system card-readers normally used to achieve and maintain continuous personnel accountability were unavailable. Initial accountability was completed by Security at 2:28 p.m. with 232 individuals reported as missing. With the accountability card-reader system unavailable EPIP 5.03 requires Security to assign two individuals to be available for accountability call-in, and to announce over the Gai-Tronics page system the need to perform manual accountability using instructions posted in each of the Emergency Assembly Areas, and to report the results to a specified telephone extension. In accordance with EPIP 5.03, Security made the personnel assignments and the page system announcement to perform manual accountability. Some of the Emergency Assembly Area leaders, however, did not follow the page system announcement to follow the instructions posted in each of the assembly areas. Posted instructions directed each assembly area leader to record the badge numbers of personnel arriving in the area on badge number sheets located in the assembly area log books and then call Security with the results. The failure to follow the posted manual accountability instructions resulted in Security conducting searches for the large number of personnel that appeared to be missing. Conducting these searches resulted in a significant delay to complete the accounting process. At 6:29 p.m. on August 23, approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and 26 minutes after the Alert declaration, the accounting process was completed. The licensee determined that some assembly area leaders were not familiar with the posted instructions resulting in the significant delay to complete the accounting process.

Analysis:

The inspectors determined that the licensees failure to follow posted Emergency Assembly Area accountability instructions was a performance deficiency and resulted in delaying completion of the personnel accountability process following the Alert declaration. 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. 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 finding was assessed for significance in accordance with NRC Inspection Manual Chapter (IMC) 0609, using the Phase I SDP worksheets for emergency preparedness 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

H.2(b).

Enforcement:

This finding does not involve enforcement action because no violation of regulatory requirements was identified. This issue has been entered into the licensees corrective action program as CR 439343. Because this finding does not involve a violation and has very low safety significance, it is identified as FIN 05000338, 339/2012004-02, Challenges to Personnel Accountability Following Declared Alert.

.3 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensees corrective action program documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment and corrective maintenance issues but also considered the results of daily inspector corrective action program item screening discussed in Section 4OA2.1. The review included issues documented outside the normal corrective action program in system health reports, corrective maintenance work orders, component status reports, site monthly meeting reports, and maintenance rule assessments. The inspectors review nominally considered the six month period of January through June 2012, although some examples expanded beyond those dates when the scope of the trend warranted.

The inspectors compared and contrasted their results with the results contained in the licensees latest integrated quarterly assessment report. Corrective actions associated with a sample of the issues identified in the licensees trend report were reviewed for adequacy.

b. Assessment and Observations No findings of significance were identified. In general, the licensee has identified trends and has addressed the trends with their corrective action program.

4OA3 Event Followup

(Closed) Licensee Event Report (LER) 05000338/2012-001-00: Degraded Reactor Coolant System Piping Due to Primary Water Stress Corrosion Cracking On March 24, 2012, with Unit 1 in Mode 6 refueling, two through-wall cracks were identified after machining the Unit 1 B steam generator hot leg nozzle. The cracking was determined to be caused by primary water stress corrosion cracking and confirmed to be fully contained with the dissimilar metal alloy 600 weld and butter. Subsequently, the B steam generator and associated reactor coolant piping were drained and the through-wall cracks were seal welded. On March 25, 2012, a non-emergency 8-hour report was made to the NRC Operator Center, in accordance with 10 CFR 50.72(b)(3)(ii)(A) for the same condition. Extent of Condition volumetric examinations were performed on the Unit 1 SG cold leg nozzles during the spring 2012 refueling outages and no flaws were identified.

An in-service inspection was performed by the NRC and the results are documented in North Anna Inspection Report 05000338/2012003 and 05000339/2012003. The enforcement aspects of this are discussed in Section 1R08 of that report. This LER is closed.

4OA5 Other Activities

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with the licensee security procedures and regulatory requirements relating to nuclear plant security.

These observations took place during both normal and off-normal plant working hours.

These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status review and inspection activities.

b. Findings

No findings were identified.

.2 Review of the Operation of an Independent Spent Fuel Storage Installation (Inspection

Procedure 60855.1)

a. Inspection Scope

Inspectors verified by direct observation, or review of selected records, that the licensee had identified fuel assemblies placed in the Independent Spent Fuel Storage Installation.

The inspectors verified that the parameters and characteristics of each fuel assembly were recorded, and that a record of each fuel assembly was made as a controlled document.

b. Findings

No findings were identified.

.3 (Discussed) NRC Temporary Instruction (TI) 2515/187, Inspection of Near-Term Task

Force Recommendation 2.3 Flooding Walkdowns, and NRC TI 2515/188, Inspection of Near-Term Task Force Recommendation 2.3 Seismic Walkdowns

a. Inspection Scope

Inspectors accompanied the licensee on a sampling basis, during their flooding and seismic walkdowns, to verify that the licensees walkdown activities were conducted using the methodology endorsed by the NRC. These walkdowns are being performed at all sites in response to a letter from the NRC to licensees, entitled Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 (ADAMS Accession No.

ML12053A340).

3 of the March 12, 2012, letter requested licensees to perform seismic walkdowns using an NRC-endorsed walkdown methodology. Electric Power Research Institute (EPRI) document 1025286 titled, Seismic Walkdown Guidance, (ADAMS Accession No. ML12188A031) provided the NRC-endorsed methodology for performing seismic walkdowns to verify that plant features, credited in the current licensing basis (CLB) for seismic events, are available, functional, and properly maintained.

4 of the letter requested licensees to perform external flooding walkdowns using an NRC-endorsed walkdown methodology (ADAMS Accession No.

ML12056A050). Nuclear Energy Industry (NEI) document 12-07 titled, Guidelines for Performing Verification Walkdowns of Plant Protection Features, (ADAMS Accession No. ML12173A215) provided the NRC-endorsed methodology for assessing external flood protection and mitigation capabilities to verify that plant features, credited in the CLB for protection and mitigation from external flood events, are available, functional, and properly maintained.

b. Findings

Findings or violations associated with the flooding and seismic walkdowns, if any, will be documented in future reports.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On October 23, 2012, the resident inspector presented the inspection results to Mr. G.

Bischof and other members of the staff, who acknowledged the findings. The inspectors asked the licensee whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.

4OA7 Licensee Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meet the criteria of Section 2.3.2 of the NRC Enforcement Policy for characterization as a NCV:

  • 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.

ATTACHMENT: SUPPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

M. Becker, Manager, Nuclear Outage and Planning
G. Bischof, Site Vice President
M. Crist, Plant Manager
J. Daugherty, Manager, Nuclear Maintenance
R. Evans, Manager, Radiological Protection
R. Garver, Manager Design & Site Engineering
B. Gaspar, Manager, Nuclear Site Services
C. Gum, Manager, Nuclear Protection Services
E. Hendrixson, Director, Nuclear Engineering
S. Hughes, Manager, Nuclear Operations
P. Kemp, Project Manager, Station Improvement Initiatives
J. Leberstien, Technical Advisor Licensing
F. Mladen, Director, Nuclear Safety and Licensing
M. Olin, Supervisor, Nuclear Emergency Preparedness
J. Plossl, Supervisor, Nuclear Station Procedures
J. Schleser, Manager, Nuclear Organizational Effectiveness
D. Taylor, Supervisor, Station Licensing
R. Wesley, Manager, Nuclear Training
L. Wilson, Supervisor, Security Operations
M. Whalen, Technical Advisor Licensing
M. Whitlock, Coordinator, Nuclear Security Programs

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened and Closed

05000338, 339/2012004-01 NCV Failure to Promptly Identify and Correct a Condition Adverse to Quality Involving Inadequate Tornado Missile Protection for a Pipe Penetration in the SWPH (Section 1R01.2)
05000338, 339/2012004-02 FIN Challenges to Personnel Accountability Following Declared Alert (Section 4OA2.2)

Closed

05000338/2012-001-00 LER Degraded Reactor Coolant System Piping Due to Primary Water Stress Corrosion Cracking (Section 4OA3)

Discussed

TI 2515/187 TI Inspection of Near-Term Task Force Recommendation 2.3 Flooding Walkdowns (Section 4OA5.3)

TI 2515/188 TI Inspection of Near-Term Task Force Recommendation 2.3 Seismic Walkdowns (Section 4OA5.3)

LIST OF DOCUMENTS REVIEWED

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