IR 05000280/2008005

IR 05000280-08-005, 05000281-08-005, on 10/01/2008 - 12/31/2008, Surry Power Station Units 1 and 2, Event Followup

ML090300516
Person / Time
Site:	Surry
Issue date:	01/30/2009
From:	Gerald Mccoy NRC/RGN-II/DRP/RPB5
To:	Christian D Virginia Electric & Power Co (VEPCO)
References
IR-08-005
Download: ML090300516 (30)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION anuary 30, 2009

SUBJECT:

SURRY POWER STATION - NRC RESIDENT INSPECTION REPORT NOS.

05000280/2008005 AND 05000281/2008005

Dear Mr. Christian:

On December 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Surry Power Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on January 12, 2009, with Mr. Bischof and other members of your staff.

The inspections examined activities conducted under your licenses as they relate 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 two self-revealing findings of very low safety significance (Green). One of these findings was determined to involve a violation of NRC requirements. Additionally, two licensee-identified violations, which were determined to be of very low safety significance, are listed in this report. However, because of the very low safety significance and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV in this report, 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 20555-0001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington D.C. 20555-0001; and the NRC Resident Inspector at the Surry 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

VEPCO 2 NRCs document 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 Docket Nos.: 50-280, 50-281 License Nos.: DPR-32, DPR-37

Enclosure:

Integrated Inspection Report 05000280/2008005 and 05000281/2008005 w/ Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-280, 50-281 License Nos.: DPR-32, DPR-37 Report No.: 05000280/2008005 and 05000281/2008005 Licensee: Virginia Electric and Power Company (VEPCO)

Facility: Surry Power Station, Units 1 and 2 Location: 5850 Hog Island Road Surry, VA 23883 Dates: October 1, 2008 through December 31, 2008 Inspectors: C. Welch, Senior Resident Inspector J. Nadel, Resident Inspector J. Reece, Senior Resident Inspector D. Arnett, Project Engineer E. Lea, Senior Operations Engineer (Section 1R11.1)

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

SUMMARY OF FINDINGS

IR 05000280/2008-005, 05000281/2008-005; 10/01/2008 - 12/31/2008; Surry Power Station

Units 1 and 2; Event Followup The report covered a three month period of inspection by resident inspectors. Two Green findings, one of which was a non-cited violation (NCV), were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, (SDP). 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.

Cornerstone: Initiating Events

Green.

A Green self-revealing non-cited violation (NCV) of Technical Specification 6.4.A.7 was identified for failure to provide adequate work instructions for corrective maintenance on the safety injection (SI) system. The inadequate work instructions led to an inadvertent actuation of the Unit 1 B train of safety injection on October 29, 2008. The proposed corrective actions are to provide guidance/restrictions in the work planning process to assure appropriate reviews are obtained, commensurate with the safety significance of the work.

The finding is greater than minor because it had an actual safety impact by causing a SI and if left uncorrected could lead to a more significant safety issue. The finding is associated with the human performance attribute of the Reactor Safety Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The finding is determined to be of very low safety significance (Green) based on a Phase 3 SDP analyses performed by a regional Senior Reactor Analyst. This finding has a cross-cutting aspect in the area of human performance, decision making, because the decision to continue with the planned work was made without a complete understanding of either the effects of the job steps or the worst case possible unintended consequences (H.1(b)). (Section 4OA3.1)

Green.

A Green self-revealing Finding was identified for failure to provide adequate vendor oversight for non-safety related work, which led to the incorrect installation of balance weights on the Unit 1 main turbine. As a result, the turbine experienced high vibrations during startup on April 20, 2008, which required the insertion of a manual turbine and reactor trip. The licensee entered the deficiency into the corrective action program for resolution (CR 096233). Corrective actions to correct the balance move, implement peer review requirements, and procedural changes that require independent verification of the balance move location and weight have been implemented. A violation of regulatory requirements was not identified.

The finding is greater than minor because it had an actual impact on safety, it led to a plant trip, and is associated with the human performance attribute of the Reactor Safety Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The finding, evaluated per Attachment 4 of the SDP, screened to very low safety significance (Green) because it did not contribute to both an initiating event and the likelihood of a loss of mitigating equipment or functions. The cause of the finding is related to the cross-cutting element of human performance work practices. Human error prevention techniques such as peer checks were not invoked by the licensee (H.4(a)). (Section 4OA3.2)

B. Licensee-Identified Violation Violations of very low safety significance which were identified by the licensee have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and corrective actions are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period operating at 100% rated thermal power (RTP). On October 27, 2008, the unit was shutdown for a planned forced outage to repair feedwater heater tube leaks. The unit was returned to full RTP on November 1, 2008, and operated at full RTP throughout the remainder of the inspection period.

Unit 2 operated at or near full RTP throughout the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection

a. Inspection Scope

Evaluation of Readiness for Cold Weather Conditions. The inspectors reviewed the licensees preparations for cold weather to verify design features and the implementation of the cold weather procedure would protect mitigating systems from the adverse effect of severe cold weather. On a sampling basis, the inspectors verified checklist items from operations surveillance procedure 0-OSP-ZZ-001 (Rev. 9), Cold Weather Preparations; were adequately performed. This included verifying proper positioning of roll-up doors, ventilation louvers, and thermostat settings in the turbine building, emergency diesel generator rooms, and the safeguard rooms. Also included were verifications that HVAC system fans were operating in the proper alignment and that piping insulation and heat tracing was installed and operable in areas within the safeguards rooms susceptible to a cold environment.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignments

.1 Partial System Walkdown

a. Inspection Scope

The inspectors performed a partial walkdown of the risk-significant systems listed below to verify the systems were correctly aligned to perform their designated safety function.

The walkdowns occurred during periods when the redundant train or system was out-of-service for maintenance and/or testing or following realignment after an extended system outage. The positions of critical valves, breakers, and control switches, required for system operability, were verified in the correct configuration by field walkdown and/or review of the main control board. To ascertain the required system configuration, the inspectors reviewed plant procedures, system drawings, the Updated Final Safety Analysis Report (UFSAR), and the Technical Specifications (TS). The documents reviewed during this inspection are listed in the Attachment.

• Common - chilled water A header during modification to the B header

• Unit 2 motor driven auxiliary feedwater (AFW) trains A & B during corrective maintenance on the turbine driven AFW pump

• #2 emergency diesel generator (EDG) following return to service after corrective maintenance for a start failure alarm

• Unit 2 low head safety injection trains A & B following surveillance testing

• Common - #3 EDG during corrective maintenance on #1 EDG for a start failure alarm

b. Findings

No findings of significance were identified.

.2 Complete Walkdown

a. Inspection Scope

The inspectors performed a detailed walkdown of the common spent fuel pit cooling (FC)system, including the spent fuel pit purification and spent fuel pit skimmer subsystems.

The purpose of this inspection was to verify the FC system was properly aligned, capable of performing its safety function, and to assess the material condition of the system.

During the walkdown, the inspectors verified valve and breaker positions were in the proper alignment, component labeling was accurate, hangers and supports were functional, local equipment status indications were accurate, and valves were locked as required. The plant health report, system drawings, plant issues documents, condition reports, the UFSAR, and Technical Specifications were reviewed. Outstanding plant issues and system deficiencies were verified to be properly classified and not affect the capability of the system to perform its safety function. The inspectors reviewed the corrective action program to verify equipment alignment issues were being identified and properly resolved. The documents reviewed during this inspection are listed in the

.

b. Findings

No findings of significance were identified.

1R05 Fire Protection

.1 Fire Protection - Tours

a. Inspection Scope

The inspectors walked down the fire areas identified below to evaluate the fire protection program operational status and material condition and the adequacy of:

(1) control of transient combustibles and ignition sources;

(2) fire detection and suppression capability;

(3) passive fire protection features;

(4) compensatory measures established for out-of-service, degraded or inoperable fire protection equipment, systems, or features; and (5)procedures, equipment, fire barriers, and systems so that the post-fire capability to safely shut down the plant is ensured. The inspectors reviewed the corrective action program to verify fire protection deficiencies were being identified and properly resolved. The documents reviewed during this inspection are listed in the Attachment.

• Fire zone 5, main control room

• Fire zone 47, Unit 2 cable spreading room

• Fire zone 45, mechanical equipment room 3

• Fire zone 54, mechanical equipment room 4

b. Findings

No findings of significance were identified.

.2 Fire Protection - Drill Observations

a. Inspection Scope

The inspectors observed a fire brigade drill held on December 4, 2008, to evaluate the readiness of the licensees personnel to fight fires. Specific aspects evaluated were: the number of individuals assigned to the fire brigade; response timeliness; use of protective clothing and self contained breathing apparatus; control room response including, identification of the fires location; dispatch of the fire brigade; sounding of alarms; brigade team leaders command and control, use of pre-fire plan strategies, briefs, and delegation of assignments; fire hose deployment and reach; approach into the fire area; effectiveness of communications among the fire brigade members and the control room; sufficiency of fire fighting equipment brought to the fire scene; search for victims; effective smoke removal; and the drill objectives and acceptance criteria. The inspectors observed the post drill critique and verified noted deficiencies and or areas for improvement were captured. The documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors reviewed the licensees flood protection measures to verify the flooding mitigation plans and equipment were consistent with the design requirements and risk analysis assumptions. The inspectors reviewed the UFSAR and the Individual Plant Examination (IPE) of Non-Seismic External Events and Fires for analyzed external and internal floods, performed walkdowns in the turbine building, emergency switchgear room, and mechanical equipment rooms 3, 4, and 5 to review compliance with procedures for internal flooding. In addition, the inspectors verified the presence of floor drain back water stop valves, various expansion joint shields, and flood and spill control dams. The inspectors reviewed the logs for posted flood watches in the emergency switch gear rooms and mechanical equipment room 3 for ongoing chilled water piping replacements and service water piping inspections and maintenance.

The inspectors reviewed a documented design deficiency for the turbine building flood control system (CR120395) and walked down the installed compensatory measures.

Sandbag dikes were installed around each motor control center (MCC) to prevent flood waters from shorting out the MCC powering each flood control system before automatic closure of the circulating water inlet isolation valves could occur. A violation of regulatory requirements was not identified.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

.1 Annual Review of Licensee Requalification Examination Results

a. Inspection Scope

On March 28, 2008, the licensee completed administering the annual requalification operating tests which are required to be given to all licensed operators in accordance with 10 CFR 55.59(a)(2). The inspectors performed an in-office review of the overall pass/fail results of the individual operating tests, as well as the crew simulator operating tests. These results were compared to the thresholds established in Manual Chapter 0609 Appendix I, Operator Requalification Human Performance Significance Determination Process.

b. Findings

No findings of significance were identified.

.2 Resident Inspector Quarterly Review

a. Inspection Scope

The inspectors observed licensed operator simulator training given on October 21, 2008.

The training was administered using scenario RQ-08.1-ST-1 (Rev. 0), and involved both operational transients and design basis events. The inspector verified that simulator conditions were consistent with the scenario and reflected the actual plant configuration (i.e., simulator fidelity). The inspector observed the crews performance to determine whether the crew met the scenario objectives; accomplished the critical tasks; demonstrated the ability to take timely action in a safe direction and to prioritize, interpret, and verify alarms; demonstrated proper use of alarm response, abnormal, and emergency operating procedures; demonstrated proper command and control; and communicated effectively. The inspector confirmed items for improvement were identified and discussed with the operators to further enhance performance.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

For the equipment issues described below, the inspectors evaluated the licensees effectiveness of the corresponding preventive and corrective maintenance. For each item below, the inspectors performed a detailed review of the problem history and associated circumstances, evaluated the extent of condition reviews, as required, and reviewed the generic implications of the equipment and/or work practice problem.

Inspectors performed walkdowns of the accessible portions of the system, performed in-office reviews of procedures and evaluations, and held discussions with system engineers. Inspectors compared the licensees actions against the requirements of the Maintenance Rule (10 CFR 50.65), VPAP 0815 Maintenance Rule Program, and the Surry Maintenance Rule Scoping and Performance Criteria Matrix.

• RM 259/RM 260 inoperability: CRs 28910, 29089, 94673

• 2-RC-SV-2551C and 2-RC-SV-2551B failed the as-found set pressure test: CRs 097633, 098450

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors evaluated the following attributes for the systems, structures, and components and activities listed below:

(1) the effectiveness of the risk assessments performed before maintenance activities were conducted;

(2) the management of the assessed risk;

(3) that, upon identification of an unforeseen situation, necessary steps were taken to plan and control the resulting emergent work activities; and

(4) that maintenance risk assessments and emergent work problems were adequately identified and resolved.

• Green risk on October 7, 2008 for planned maintenance on the control room air handling units (1/2 VS-AC-7)

• Green risk on October 22, 2008 for emergent work on the Unit 2 turbine and motor driven AFW trains

• Green risk on November 3, 2008 for emergent work on EDG #2 following an unanticipated start failure alarm

• Green risk on December 3, 2008 for emergent work to replace a failed test switch in the Unit 2 SI logic cabinet

• Green risk on December 7-8, 2008 for emergent work on #1 EDG following an unanticipated start failure alarm

• Green risk on December 29, 2008 for the unanticipated inoperability of the B train of recirculation spray

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed operability evaluations affecting risk significant 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;

(4) if compensatory measures were involved, whether the compensatory measures were in place, would work as intended, and were appropriately controlled; and

(5) where continued operability was considered unjustified the impact on TS limiting condition for operations. The inspectors reviewed the following immediate operability determinations/operability evaluations:

• CR 113792, U1/U2 containment spray system chemical addition line piping voids

• CR 117266, common mode failure evaluation for #2 EDG start failure alarm

• CR 117485, inoperable support for #2 EDG vent piping

• CR 115260, incorrect filler weld material used on Unit 2 AFW recirculation flow orifice installation

• CR 114952, 1-CH-P-1B is mounted with 3 bolts versus the design of four bolts

• CR 118661, service water through wall leak on class 3 discharge pipe from 1-VS-E-4C

• CR 119375, service water through wall leak at weld upstream 1-SW-934

• CR 117901, oil leak from residual heat removal pump 2-RH-P-1B

• CR 119861, low fluid level on snubber 1-RC-HSS-112 for 1-RC-SV-1551B

• CR 114600, lack of fusion welds in NUHOMS cask

• CR 120278, LHSI pump suction piping void

b. Findings

No findings of significance were identified.

1R18 Plant Modifications

a. Inspection Scope

The inspectors reviewed the temporary modifications listed below to verify that the modifications did not affect the systems safety function or its operability/availability, that the design and licensing bases, and performance capability of risk significant SSCs was not degraded; and to verify that modifications performed during increased risk-significant configurations do not place the plant in an unsafe condition. Documents reviewed included procedures, engineering calculations, modification design and implementation packages, 10 CFR 50.59 reviews, work orders, site drawings, corrective action documents, applicable sections of the UFSAR, supporting analyses, TS, and design basis information. The inspectors witnessed aspects of each modification implementation and observed aspects of post-modification testing of the temporary modifications to verify adequate testing of the changes.

• Temporary Modification, TM S2-08-062, for a jumper installed to allow replacement of both primary and secondary coil conductors for Rod H2

• Temporary Modification, TM S2-08-065, for installation of a jumper to maintain the J1 daisy chain of the SI circuit during test switch replacement

b. Findings

No findings of significance were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors observed and/or reviewed the post-maintenance test (PMT) procedures and/or test activities, as appropriate, for selected risk significant systems to assess whether:

(1) plant testing 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 its safety function. The inspectors observed and/or reviewed the PMT for the following maintenance activities:

• WO 38102442543: #2 EDG air start component replacement

• WO 38102459397: replace test switch 02-SI-CS-PC457DTA

• WO 38102436679, 38102436620: perform weld repairs on auxiliary feedwater orifice welds 02-FW-RO-200A-pipe

• WO 38102435930, 38102436594: perform weld repairs on auxiliary feedwater orifice welds 02-FW-RO-200B-pipe

• WO 38079023801, 38079023701, 38102358384, 38102351328, 38051706501, 38073765902, 38077942501, 38102141628: mechanical maintenance work orders to support 18 month preventive maintenance on #3 EDG

• WO 38102195955, 38102195996, 38102195185, 38102196023, 38102196009, 38102195968: electrical work orders to support 18 month preventive maintenance of

1. 3 EDG

• WO 38102268413,38102270499, 38102401573, 38102268395, 38102243268, 38052863401, 38102268507, 38102268440, 38102268431, 38102268458, 38102268449 38102268404, 38102268498, 38102268467, and 38102268517: relay replacements performed in support of 18 month preventive maintenance on #3 EDG

• WO 38076274501: change oil on 02-CS-P-1B

b. Findings

No findings of significance were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

A forced outage was conducted from October 27 to November 1, 2008, to repair excessive tube leakage in the Unit 1 6th point feedwater heater (1-FW-E-6B). The inspectors observed evolutions to shutdown the reactor and place the unit into an Intermediate Shutdown Mode. The inspectors verified TS cooldown limits were not exceeded, and on a sampling basis, verified plant risk assessments were accurate, and that TS requirements for mode changes were met. Licensee calculations for shutdown margin and the estimated position for criticality were reviewed and checked against independent calculations performed by the inspectors. Evolutions to startup and place the unit on-line were observed by the inspectors and on a sampling basis TS requirements associated with the mode changes and heat-up limits were verified.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors witnessed surveillance tests and/or reviewed test data for the risk-significant SSCs listed below to assess, as appropriate, whether the SSCs met TS, the UFSAR, and licensee procedural requirements. The inspectors also determined if the testing effectively demonstrated that the SSCs were ready and capable of performing their intended safety functions.

Surveillance Tests

• 2-OPT-EG-001 (Rev 49): EDG #2 Monthly Start Exercise Test

• SP IP 10 (Rev 9): Physical Security Barrier Protection

• 2-IPT-FT-RP-SI-001A (Rev 13 OTO1): Train A Safeguards Actuation Logic Functional Test In-service Tests

• 0-OPT-SW-001 (Rev 38): Emergency Service Water Pump 1-SW-P-1A

• 2-OPT-CS-002 (Rev 13): Containment Spray System Test Reactor Coolant Leakage

• 1-OPT-RC-10 (Rev 23): Reactor Coolant Leakage - Computer Calculated

• 2-OPT-RC-10 (Rev 25): Reactor Coolant Leakage - Computer Calculated

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator (PI) Verification

Cornerstone: Mitigating Systems

The inspectors reviewed, on a sampling basis, the Mitigating Systems Performance Index (MSPI) performance indicators for Units 1 and 2 for the fourth quarter of 2007 through the third quarter of 2008. The purpose of the review was to assess the accuracy and completeness of the submitted PI data and whether the performance indicators were calculated in accordance with the guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline. The evaluation included verification of compliance with the licensees NRC Mitigating System Performance Index Basis Document, and review of selected consolidated entry forms for accuracy of information entered into the MSPI calculation computer program. Data reviewed for the monitored components included unavailability, reliability and run times; the number of starts, and failures to start and run. Information from logs and other plant documentation was used to verify the data was accurate. The data gathering and entry was discussed with cognizant personnel. This inspection activity represents the following 10 samples.

• Unit 1 and 2 Emergency AC Power System

• Unit 1 and 2 High Pressure Injection System

• Unit 1 and 2 Cooling Water System

• Unit 1 and 2 Heat Removal System

• Unit 1 and 2 Residual Heat Removal System

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Review of Items Entered into the Corrective Action Program:

a. Inspection Scope

As required by Inspection Procedure 71152, Identification and Resolution of Problems, and in order to help identify repetitive, long-term, or latent equipment failures, or specific human performance issues for follow-up; the inspectors performed a daily screening of items entered into the licensees corrective action program. The reviews were accomplished by either reviewing hard copies of each condition report, attending daily screening meetings, and/or accessing and reviewing the licensees computerized database.

b. Findings

No findings of significance were identified.

.2 Semi-Annual Trend Review

a. Inspection Scope

As required by Inspection Procedure 71152, Identification and Resolution of Problems, the inspectors performed a review of the licensees corrective action program and associated 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. The review also included issues documented outside the normal correction action program in system health reports; corrective maintenance works orders, component status reports, site monthly meeting reports and maintenance rule assessments. The inspectors review nominally considered the six-month period of July 1, 2008 through December 17, 2008. 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. Findings

No findings of significance were identified. In general, the licensee has identified trends and has appropriately addressed the trends with their CAP.

.3 Annual Sample: Containment Airborne and Particulate Radiation Monitor Failures

a. Inspection Scope

The inspectors performed an in-depth review of the containment airborne and particulate radiation monitor (RM 259/260) failures that occurred from January 2007 to September 2008. This inspection focused on the history of radiation monitor flow failures, filter failures, and heat trace issues that led to multiple inoperabilities over a long period of time. Specifically, the monitors treatment under the maintenance rule was investigated.

This issue was selected for review because of the industry-wide recognition of the importance of having separate and diverse methods of RCS leak detection and because of the technical specification requirements associated with these radiation monitors.

The inspectors, on a sampling basis, reviewed maintenance rule evaluations (MRE);apparent cause evaluations (ACE); searched the condition reporting (CR) and plant issues (PI) systems; and reviewed related CRs; and interviewed licensee personnel. The inspectors assessed licensee performance in addressing each of the following attributes:

• Complete and accurate identification of the problem in a timely manner

• Evaluation and disposition of operability/reportability issues

• Consideration of extent of condition, generic implications, common cause, and previous occurrences

• Classification and prioritization of the resolution of the problem commensurate with its safety significance

• Identification of corrective actions which are appropriately focused to correct the problem

• Completion of corrective actions in a timely manner commensurate with the safety significance of the issue

• Implementation of interim corrective actions and/or compensatory measures to minimize the problem and/or mitigate its effects, until permanent action can be implemented, and

• Evaluation of equipment failures under the maintenance rule

b. Findings

No findings of significance were identified.

.4 Review of Operator Workarounds

a. Inspection Scope

The inspectors performed an in-depth operator workaround review to verify the licensee was identifying operator workaround problems at an appropriate threshold and entering them into the corrective action program, and had proposed or implemented appropriate corrective actions. The inspectors evaluated whether the workarounds could affect multiple mitigating systems and whether the cumulative effects of operator workarounds on the reliability, availability, and potential for misoperation of a system adversely impacted on the ability of operators to respond in a correct and timely manner to plant transients and accidents. The inspection was accomplished by document reviews, plant tours, and interviews with licensed and non-licensed operators. The inspection focused on identification of risk significant operator workarounds involving mitigating systems to determine if the mitigating system functions and or operators ability to implement abnormal and emergency operating procedures was affected. Workarounds, formalized as long-term corrective action for a degraded or non-conforming condition were also sought out and particular attention given to identifying workarounds that increased the potential for personnel error, or:

• Require operations contrary to past training or require more detailed knowledge of system than routinely provided

• Require a change from longstanding operational practices

• Require operation of a system or component in a manner dissimilar from similar systems or components

• Create the potential for the compensatory action to be performed on equipment under conditions for which it is not appropriate

• Impair access to required indications, increase dependence on oral communications, or

• Require actions under adverse environmental conditions, and require the use of equipment and interfaces that had not been designed with consideration of the task being performed

b. Findings and Observations

No findings of significance were identified that adversely impacted the ability of operators to respond in a correct and timely manner to plant transients and accidents. One-of-two Unit 1 pressurizer power operated relief valves (PORVs) was isolated due to valve seat leakage. Adequate procedural guidance exists for the main control room operator to open the block valve and restore the PORV to service if necessary.

4OA3 Event Followup

.1 Unit 1 Inadvertent Safety Injection

a. Inspection Scope

The inspectors reviewed the plant response and operator performance for the inadvertent safety injection (SI) that occurred on October 29, 2008 at 6:04 PM. The inspection objectives were to verify safety equipment responded properly, the plant responded as expected, and that the safety injection was not the result of or complicated by human performance error. The main control room operating crews response was assessed; work packages, procedures, control room logs were reviewed; and operations and I&C personnel were interviewed.

b. Findings

Introduction.

A Green self-revealing NCV was identified for the failure to comply with Technical Specification 6.4.A.7 in that the use of inadequate work instructions led to the inadvertent actuation of the Unit 1 B train of safety injection.

Description.

On October 29, 2008, while conducting a planned work activity to replace a broken light bulb on the Unit 1 safety injection status panel, per work order 38079597601, the B train of safety injection actuated and injected approximately 300 gallons of water into the reactor coolant system (RCS) cold leg. The unit was in intermediate shutdown mode with RCS temperature < 350°F and RCS pressure approximately 300 psi. The invalid SI actuation was terminated quickly by control room operators.

The work was performed in accordance with instructions created under the work control process for inserting job steps directly into the work order. This process includes developing procedure steps within the work order by collaboration between the planners and the shop immediately involved in the work. In work planning, this is the least formal option and there are no requirements for additional reviews or concurrence on the job steps by other onsite organizations.

The work instructions provided were not adequate because they failed to properly isolate the circuit. As a result, when the leads to the light socket with the broken bulb were lifted, a voltage imbalance within parallel circuits was created which allowed sufficient current to flow through the master relay for SI train B, which caused the relay to pick up and actuate.

The inspectors concluded that the work planning process program was deficient in that it lacked clear guidance and restrictions on when a certain work planning option could be chosen in lieu of another. Given that some of the other planning options include more stringent requirements and higher levels of review, the collaborative work control process of was not appropriate to the circumstances or commensurate to the safety significance of the plant equipment in this case.

Analysis.

The inspectors determined the failure to provide adequate work instructions for the corrective maintenance on the SI system was a performance deficiency. The finding is greater than minor because it had an actual impact by causing a SI and if left uncorrected could lead to a more significant safety issue. The finding is associated with the human performance attribute of the Reactor Safety Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The finding was determined to be of very low safety significance (Green) based on a Phase 3 SDP analysis performed by a regional Senior Reactor Analyst. The analysis was accomplished by increasing the initiating event frequency for a stuck open power operated relief valve (PORV), Table 3.4 of the Phase 2 at-power Notebook, by one order of magnitude and solving the accident sequences, two of which totaled seven. The sequences involved the SI causing a pressurizer PORV to fail open and a failure of the block valve to close and isolate the loss of coolant and, the failure of either high pressure injection or low pressure recirculation. Key assumptions were: 1)due to the low decay heat the disabled mitigation equipment could be easily restored to service from the Main Control Room by simple operator action and were therefore available for accident mitigation and 2) the contribution of an external event, though considered, was not quantified due to the low initiating event frequency and the short duration of the SI event, would result in an extremely low risk contribution.

The inspectors identified a crosscutting aspect to this finding in the area of human performance, decision making, because the decision to continue with the planned work was made without a complete understanding of either the effects of the job steps or the worst case possible unintended consequences (H.1(b)).

Enforcement.

Technical Specification 6.4.A.7 requires in part, that detailed written procedures with appropriate instructions be provided for corrective maintenance which would have an affect on the safety of the reactor. Contrary to the above, on October 29, 2008, the licensee failed to provide appropriate instructions for the performance of corrective maintenance on the B train of the Unit 1 safety injection system causing the inadvertent actuation of the B train of safety injection. Proposed corrective action to provide additional guidance and restrictions in the work planning process appear appropriate. Because this violation was of very low safety significance and it was entered into the licensees corrective action program (CR116664), this violation is being treated as a NCV, consistent with the NRC Enforcement Policy: NCV 05000280/2008005-01, Inadequate Work Instructions Result in Actuation of Unit 1 Safety Injection Train B.

.2 (Closed) LER 05000280/2008-001-00. Turbine Vibration Results in Manual Trip.

a. Inspection Scope

The inspectors reviewed Licensee Event Report (LER) 05000280/2008-001-00 and related documents to assess the LERs accuracy, appropriateness of the corrective actions, potential violation of NRC requirements, and generic issues.

b. Findings

Introduction.

A Green self-revealing Finding was identified for failure to provide adequate vendor oversight for non-safety related work, which led to the incorrect installation of balance weights on the Unit 1 main turbine. As a result, the turbine experienced high vibrations during startup on April 20, 2008, which required the insertion of a manual turbine and reactor trip. A violation of regulatory requirements was not identified (CR 096233).

Description.

In the Surry Unit 1 2007 RFO Turbine and Startup Balance Report.

Siemens recommended that that additional balance moves be made to the Unit 1 main turbine at the next available opportunity to further reduce turbine vibrations during startup. Specifically, they recommended balance moves be made on planes 4 and 5 in LP1 and plane 6 in LP2. Following the outage, the recommended balance moves were entered into Surrys outage report by a member of the turbine group responsible for reviewing the Siemens report. In April 2008, while the unit was down for a forced outage, station management authorized making balance moves on the Unit 1 main turbine as recommended by Siemens. The balance moves were made based on the information provided in the Surry outage report. On turbine startup, vibrations were higher than expected and were also higher than prior to making the balance moves. After consulting with the on-scene Siemens representative and believing the vibrations would improve once the turbine generator was loaded, power ascension was authorized to continue. At 54% reactor power and 415 MWE, vibration on the #4 turbine bearing was 13.76 mils and increasing, operations terminated the power ascension and initiated a rapid load reduction per AP-23. Due to sustained vibrations greater than 14 mils, the reactor and turbine were manually tripped at 37% reactor power and 280 MWE.

The inspectors identified a performance deficiency existed in that the licensee failed to provide adequate oversight of the vendor when they failed to perform an adequate review of the Siemens report. Specifically, the licensee did not adequately review and validate the information provided by the vendor that was within its capability to do so, as outlined in PI-AA-HU-ENG-1011 (Rev. 2), Human Performance Tools for Engineering.

In the three page report, Siemens recommended that balance moves be made on planes 4 and 5 in LP 1 and plane 6 in LP2. However, plane 5 exists in LP2, not LP1, as shown in the drawing provided in the report. Additionally, the recommended move on plane 5 in LP2 was not consistent with the reports earlier statements in regard to the balance move made on plane 5 in LP2 coming out of the 2007 RFO. The inspectors determined that had an adequate review been performed of the Siemens report and in particular of the recommended balance moves, Siemens typographical error would have been noted and questioned. Specifically, since plane 5 exists only in LP2 and therefore a balance move on plane 5 in LP1 cannot be accomplished. Identification of the error or inconsistency would have required engaging Siemens for resolution and ultimately correction of the error. The correct balance moves were to planes 3 (not 5) and 4 in LP1 and plane 6 in LP2. Contributing factors included the lack of independent verification or peer review of the recommended balance moves on the part of both Siemens and the licensee.

The inspector found that the LER was accurate and that appropriate corrective actions were taken. Corrective actions included performing the correct balance move, implementation of peer review requirements, and procedural changes that require specifying the detailed location and weight for balance moves along with an independent verification. This event was previously discussed in NRC IR 2008-003.

Analysis.

The inspectors determined that the failure to adequately review the vendors recommended balance moves was a performance deficiency and is greater than minor because it led to a plant transient. The finding is associated with the human performance attribute of the Reactor Safety Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The finding, evaluated per Attachment 4 of the SDP, screened to very low safety significance (Green) because it did not contribute to both an initiating event and the likelihood of a loss of mitigating equipment or functions.

This finding has cross cutting aspects in the area of human performance work practices.

Adequate human error prevention techniques such as peer checks were not invoked by the licensee (H.4(a)).

Enforcement.

Enforcement action does not apply because the performance deficiency did not involve a violation of a regulatory requirement. This issue was entered into the licensees corrective action program as CR 096233. Because this finding does not involve a violation of regulatory requirements and has very low safety significance, it is identified as: FIN 05000280/2008005-02, Inadequate Review of Vendor Information Led to Unit 1 Manual Reactor Trip. This LER is closed

.3 (Closed) LER 05000281/2008-001-00. Pressurizer Safety Valves Fail as Found Setpoint

The licensee reported that on that on May 2, 2008; the Unit 2 pressurizer safety valve (PSV) 2-RC-SV-2551C as found lift pressure was 2386 psig, 4.7% below the nominal value and on May 9, PSV 2-RC-SV-2551B as found lift pressure was 2399 psig, 3.5%

below nominal. The inspector found the LER was accurate and the corrective actions appropriate. A licensee-identified violation is documented in 4OA7 of this report. This LER is closed.

.4 (Closed) LER 05000280 & 281/2008-002-00. Relay Failure Results in Emergency

Diesels Auto-Starting On May 17, 2008, with Unit 1 at 100% power and Unit 2 in cold shutdown for refueling, a partial loss of off-site power occurred due to a defective relay in the switchyard.

Emergency diesel generators #2 and #3 automatically started as designed and re-energized safety buses 2H and 1J. The licensee captured the event in CR 099403 and ACE 013767. The licensee identified the cause for the relay failure, replaced and tested the relay, and instituted reasonable actions to prevent recurrence. The inspector found the LER was accurate and the corrective actions appropriate. No findings of significance were identified and no violation of NRC requirements occurred. This event was reviewed and previously discussed in NRC IR 2008-003. This LER is closed.

4OA5 Other Activities

.1 (Closed) URI 05000280, 281/2008004-02, Service Water Silting in the Charging Pump

Lube oil Coolers and TCVs The inspectors completed review and characterization of URI 05000280, 281/2008004-02 and determined the licensees failure to establish adequate corrective actions to preclude repetition of fouling in the service water (SW) portion of the lube oil cooling subsystem of the high head safety injection charging pumps was not a performance deficiency. The prior fouling events did not cause the pump to be inoperable nor were they characterized as a significant condition adverse to quality by the licensee. The high thrust bearing temperature which occurred when cooling water flow through the lube oil cooler (2-CH-E-5C) was blocked on February 22, 2008, due to silt plugging the SW temperature control valve (TCV) 2-SW-TCV-208A (CR 091548) is a significant condition adverse to quality. This item is closed.

.2 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 licensee security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal working hours.

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

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On January 12, 2009, the inspection results were presented to Mr. Bischof and members of his staff who acknowledged the findings. The inspector asked the licensee whether any proprietary material examined during the inspection was not returned. No proprietary information was identified.

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) were identified by the licensee and are a violation of NRC requirements which meet the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as NCVs.

• Technical Specification 6.4 A.1 requires, in part, that detailed written procedures with appropriate check-off lists and instructions shall be provided for the operation of components involving nuclear safety of the station. Licensee procedure GMP-012, Roving Flood Watch Responsibilities, requires that the water tight door to mechanical equipment room (MER) #3 be closed or monitored. Contrary to the above, on October 20, 2008, the watertight door to MER #3 was found open and unattended. This issue was identified in condition report 115052. This finding is of very low safety significance based on the results of a Phase 3 significance determination process.

• Technical Specification 3.1.A.3.b requires the pressurizer safety valves (PSV) as found lift pressure setpoint be within +/- 3% of nominal 2485 psig. Contrary to the above, on May 2, 2008 the Unit 2 PSV 2-RC-SV-2551C as found lift pressure was 4.7% below the nominal value and on May 9, PSV 2-RC-SV-2551B as found lift pressure was 3.5% below nominal. This issue was identified in CR 097633 and ACE 013757. This finding is of very low safety significance because the PSVs were capable of performing their safety function, and operation with the low as-found lift setpoints were within the limits assumed in the accident analysis ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Adams, Director, Station Engineering

G. Bischof, Site Vice President

B. Garber, Supervisor, Licensing

K. Grover, Manager, Operations

A. Harrow, Supervisor Electrical Systems

R. Johnson, Manager, Outage and Planning

L. Jones, Manager, Radiation Protection and Chemistry

R. Manrique, Supervisor Primary Systems

C. Olsen, Manager Site Engineering

L. Ragland, Supervisor Health Physics Operations

R. Simmons, Manager, Maintenance

K. Sloane, Plant Manager (Nuclear)

B. Stanley, Director, Station Safety and Licensing

M. Wilda, Supervisor Auxiliary Systems

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000280/2008005-01 NCV Inadequate Work Instructions Result in Actuation of Unit 1 Safety Injection Train B (Section 4OA3.1)

05000280/2008005-02 FIN Inadequate Review of Vendor Information Led to Unit 1 Manual Reactor Trip (Section 4OA3.2)

Closed

05000280/2008-001-00 LER Turbine Vibration Results in Manual Trip (Section 4OA3.2)

05000281/2008-001-00 LER Pressurizer Safety Valves Fail as Found Setpoint (Section 4OA3.3)

05000280, 281/2008-002-00 LER Relay Failure Results in Emergency Diesels Auto-Starting (Section 4OA3.4)

05000280, 281/2008004-02 URI Service Water Silting in the Charging Pump Lube oil Coolers and TCVs (Section 4OA5.1)