IR 05000280/2010003

IR 05000280-10-003 & 05000281-10-003 on 04/01/2010 - 06/30/2010 for Surry Power Station, Units 1 and 2: Maintenance Effectiveness, Maintenance Risk Assessments and Emergent Work Control

ML102090659
Person / Time
Site:	Surry
Issue date:	07/28/2010
From:	Gerald Mccoy NRC/RGN-II/DRP/RPB5
To:	Heacock D Virginia Electric & Power Co (VEPCO)
References
IR-10-003
Download: ML102090659 (30)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION uly 28, 2010

SUBJECT:

SURRY POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000280/2010003 and 05000281/2010003.

Dear Mr. Heacock:

On June 30, 2010, the United States 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 July 21, 2010, with Mr. Bischoff and other members of your staff.

The inspection 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 one self-revealing finding, and one NRC-identified finding of very low safety significance (Green) of which one finding was determined to be a violation of NRC requirements. However, because of the very low safety significance of this issue and because it was entered into your corrective action program, the NRC is treating this as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV, 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, DC 20555-0001; and the NRC Resident Inspector at the Surry Power Station.

In addition, if you disagree with the cross-cutting aspect assigned to any finding 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, RII, and the NRC Senior Resident Inspector at the Surry Power Station.

VEPCO 2 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 document system (ADAMS). ADAMS is accessible from the NRC Website 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:

Inspection Report 05000280/2010003 and 05000281/2010003 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-280, 50-281 License Nos.: DPR-32, DPR-37 Report No: 05000280/2010003 and 05000281/2010003 Licensee: Virginia Electric and Power Company (VEPCO)

Facility: Surry Power Station, Units 1 and 2 Location: 5850 Hog Island Road Surry, VA 23883 Dates: April 1, 2010 through June 30, 2010 Inspectors: C. Welch, Senior Resident Inspector J. Nadel, Resident Inspector T. Lighty, Project Engineer Approved by: Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000280/2010-003 and 05000281/2010-003; 04/01/2010 - 06/30/2010; Surry Power

Station, Units 1 and 2: Maintenance Effectiveness, Maintenance Risk Assessments and Emergent Work Control.

The report covered a 3 month period of inspection by resident inspectors. Two Green findings were identified one of which was 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.

Cornerstone: Initiating Events

Green.

A self-revealing Green Finding was identified for failure to adequately rig a 300 pound motor in the auxiliary building in accordance with the manufacturers recommendations on May 11, 2010. As a result, the motor slipped from its rigging and dropped approximately 15 feet onto the A component cooling water (CCW) pump motor below, damaging the motors cabling and electrical junction box. The CCW pump was declared inoperable (CR 380834), the damage was repaired, and the CCW pump restored to an operable status on May 15, 2010.

Inspectors determined that the failure to implement adequate rigging practices in accordance with vendor recommendations as required by procedure MA-AA-101, Revision 5, Fleet Lifting and Material Handling constituted a performance deficiency and a finding which was reasonably within the licensees ability to foresee and correct and which should have been prevented. The finding is similar to MC 0612, Appendix E example 4.f, and is more than minor because it resulted in damage to and inoperability of a risk significant component. The finding is associated with the human performance attribute of the initiating events cornerstone and adversely affected the cornerstone objective to limit the likelihood of those events which upset plant stability and challenge critical safety functions during shutdown as well as power operations because a loss of the component cooling water system would have resulted in a unit transient. The finding, evaluated per Attachment 4 of MC-0609, Phase 1 - Initial Screening and Characterization of Findings, was determined to be of very low safety significance (Green)because it did not contribute to both the likelihood of a plant transient and the loss of accident mitigation equipment. This finding has a cross-cutting aspect in the area of human performance, decision making because the licensee did not make safety/risk significant decisions using a systematic process, especially when faced with uncertain decisions, to ensure safety is maintained (H.1(a)). Specifically, the rigging team made safety/risk significant decisions within lifting/rigging procedures that did not include a systematic process for evaluating each lift, especially loads <5000 lbs in the vicinity of risk significant equipment.

Cornerstone: Mitigating Systems

Green.

The NRC identified a Green Non-Cited Violation of 10CFR50.65 a(2) for the licensees failure to demonstrate that the reliability of High Safety Significant (HSS) systems and Low Safety

Significant (LSS) systems in stand-by was being effectively controlled through the performance of appropriate preventative maintenance, such that the systems or components remain capable of performing their function. Specifically, the licensees MR program would not demonstrate that a system should remain in category a(2) as defined by regulatory requirements.

The inspectors determined the licensees MR program could not demonstrate that reliability of High Safety Significant (HSS) systems and Low Safety Significant (LSS) systems in stand-by were being effectively controlled through the performance of appropriate preventative maintenance, such that the systems or components remain capable of performing their function is a performance deficiency. Specifically, the monitoring established by the license did not effectively demonstrate that systems in a(2) were being effectively controlled through performance of appropriate preventative maintenance. This masking of poor equipment performance does not allow the licensee to determine if a system should be in increased monitoring of a(1).

The finding was more than minor because it adversely affected the equipment performance attribute of the reactor safety mitigating systems cornerstone, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of HSS and LSS systems to perform their functions when required. Specifically, multiple HSS and LSS systems could have a high probability of failure, because poor equipment performance would not be recognized by the licensee. This could prevent a poor performing system from being placed into the a(1) category when required and appropriate corrective action would not be taken.

The finding was evaluated using MC-0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, and determined to be of very low safety significance (Green),

because the finding did not involve an actual failure of equipment. This finding had a cross-cutting aspect in the area of human performance and resources because the licensee did not ensure that personnel, procedures, and other resources were available and adequate to assure proper implementation of MR program. The MR personnel did not have the training required to implement the program within the required industry regulations and guidelines (H.2.b).

(Section 1R12)

Licensee Identified Violations

None

REPORT DETAILS

Summary of Plant Status

Unit 1 operated at or near full rated thermal power (RTP) until June 8, 2010, when a maintenance error led to an automatic reactor trip and safety injection. Following repairs, the reactor was restarted on June 11, 2010, and the Unit reached full RTP on June 12, 2010, where it operated for the remainder of the inspection period.

Unit 2 operated at or near full rated thermal power (RTP) throughout the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Evaluations of Offsite and Alternate AC Power Systems Readiness for Summer Loading

a. Inspection Scope

The inspectors reviewed plant features and station procedures for the offsite and alternate AC power systems to verify measures to monitor and maintain availability and reliability of the AC power systems were established and that communication protocols between the transmission system operator (TSO) and licensee were appropriate and addressed:

• Actions to be taken when notified by the TSO that the post-trip voltage of the offsite power system (OSP) at the nuclear power plant (NPP) will not be acceptable to assure continued operation of safety-related loads without transferring to the onsite power supply;

• Compensatory actions identified to be performed if it is not possible to predict the post-trip voltage at the NPP for current grid conditions;

• Required re-assessment of plant risk based on maintenance activities which could affect grid reliability, or the ability of the transmission system to provide OSP; and

• Required communications between the NPP and TSO when changes at the NPP could impact the transmission system or when the capability of the transmission system to provide adequate OSP is challenged.

The inspectors walked down the offsite (switchyard) and onsite alternate AC power systems and reviewed outstanding corrective maintenance work orders, condition reports, and the system health reports to assess their material conditions. The inspectors reviewed CR 375074, 0-AP-10.18 not entered upon notification by system operator that the real-time contingency analysis program was not available to predict operability of the off-site power supply to the plant.

b. Findings

No findings were identified.

.2 Seasonal Readiness Reviews for Hot Weather

a. Inspection Scope

The inspectors reviewed the licensees preparations for seasonal hot weather.

Inspection focused on verification of design features and implementation of the licensees procedure for hot weather conditions, 0-OSP-ZZ-003; Hot Weather Preparation. The inspectors walked down key structures (i.e. the turbine and auxiliary buildings, safeguards buildings, the fire pump house, the emergency switch gear rooms, and emergency battery rooms) and verified HVAC systems were operating properly and that area temperatures remained within design requirements specified in the UFSAR. The mitigating systems reviewed during this inspection include: the auxiliary feedwater systems, the refueling water storage tanks, emergency diesel generators, and emergency switchgear.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Partial Walkdown

a. Inspection Scope

The inspectors performed a partial walk down on the five risk-significant systems identified below to verify the redundant or diverse train for equipment removed from service was operable and/or that the system was properly aligned to perform its designated safety function following an extended outage. During the walkdown, the inspectors verified the positions of critical valves, breakers, and control switches by in-field observation and/or review of the main control board. To determine the correct configuration to support system operation, the inspectors reviewed applicable operating procedures, station drawings, the Updated Final Safety Analysis Report, and the Technical Specifications. During the walkdown, the inspectors attempted to identify any discrepancies that could impact the function of the system, and, therefore, potentially increase risk.

• EDG #3 following the failure of EDG #2 to run on April 19.

• B train of Unit 2 charging component cooling water during maintenance, on April 27, on charging component cooling water pump 2-CC-P-2A.

• B train of Unit 2 containment spray during maintenance, on April 28, on containment spray pump 2-CS-P-1A.

• B train of Unit 1 containment spray during maintenance, on May 6, on containment spray pump 1-CS-P-1A.

• Unit 2, turbine driven auxiliary feedwater train following restoration from testing on May 31.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Quarterly Fire Protection Reviews

a. Inspection Scope

The inspectors conducted a defense-in-depth (DID) review for the six fire areas listed below by walkdown and review of licensee documents. The reviews were performed 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 post-fire capability to safely shutdown the plant is ensured. The inspectors reviewed the corrective action program to verify fire protection deficiencies were being identified and properly resolved.

• Fire zone 9, 1A Battery Room

• Fire zone 12, 2B Battery Room

• Fire zone 46, Unit 1 Cable Spreading Room

• Fire zone.47, Unit 2 Cable Spreading Room

• Fire zone 66, Mechanical equipment Room 5

• Fire zone 55, Technical Support Center

b. Findings

No findings were identified.

.2 Annual Fire Drill

a. Inspection Scope

The inspectors observed a fire brigade drill held on May 18, 2010, to evaluate the readiness of the licensees personnel to fight fires. Aspects considered in the evaluation include: the control room operators response, including identification of the fire location, dispatch of the fire brigade, sounding of alarms, emergency procedure use, and appropriate emergency declarations; the number of individuals assigned to the fire brigade; response timeliness; use of protective clothing and self-contained breathing apparatus; the 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 brigade members and between the brigade and the control room; requests for offsite assistance; search for victims, smoke evacuation, and the drills objective and acceptance criteria. The inspectors observed the post drill critique and verified noted deficiencies or areas for improvement were captured.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

Underground Electrical Cable Bunker/Manhole inspections

a. Inspection Scope

The inspectors performed the annual review of electrical cables run underground via bunkers/manholes and buried conduit. The purpose of the inspection was to determine if the cables and cable splices appear intact and whether they were submerged or subject to periodic wetting, if the cable supports were in good condition, and if the manhole was outfitted with a means of dewatering (i.e. sump pump) and if it was operational. To accomplish this inspection, the inspectors reviewed 0-MCM-1207-01, Pumping of Security and Electrical Cable Vaults. The licensees corrective action system was also reviewed for both recent issues and the status of corrective actions from past issues. The inspectors observed the licensees inspection of three safety related manholes, two of which had permanently installed sump pumps.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

Resident Inspector Quarterly Review

a. Inspection Scope

The inspectors observed an evaluated licensed operator simulator exercise given on April 27, 2010 using scenario RQ-10.3-SP-1 (Rev. 0). The scenario 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; communicated effectively; and appropriately classified events per the emergency plan. The inspector observed the evaluators post scenario critiques and confirmed items for improvement were identified and discussed with the operators to further enhance performance.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

For the two equipment issues described in the condition reports listed below, the inspectors evaluated the effectiveness of the corresponding licensee's preventive and corrective maintenance. 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(s). Inspectors performed walkdowns of the accessible portions of the system, performed in-office reviews of procedures and evaluations, and held discussions with system engineers. The inspectors compared the licensees actions with the requirements of the Maintenance Rule (10 CFR 50.65), station procedures ER-AA-MRL-10, Rev. 4, Maintenance Rule Program; and ER-AA-MRL-100, Rev. 1, Implementing the Maintenance Rule; the Surry Maintenance Rule Scoping and Performance Matrix. And industry guidance contained in NUMARC 93-01, Rev. 2, Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants.

• CR 363782, Containment Vacuum Pump 1A tripped after running for 15 seconds

• CR 374103, EDG #1 failed to start during 1-OPT-EG-001 The inspectors examined the periodic evaluation report for January 1, 2008, to June 30, 2009. To evaluate the effectiveness of (a)(1) and (a)(2) activities, the inspectors examined a number of corrective action program CRs and work orders (WOs).

b. Findings

Introduction:

The NRC identified a Green Non-Cited Violation of 10CFR50.65 a(2) for the licensees failure to demonstrate that the reliability of High Safety Significant (HSS) systems and Low Safety Significant (LSS) systems in stand-by was being effectively controlled through the performance of appropriate preventative maintenance, such that the systems or components remain capable of performing their function. Specifically, the licensees MR program would not demonstrate that a system should remain in category a(2) as defined by regulatory requirements.

Description:

The inspectors reviewed condition reports (CR363784, CR363782, CR364648, CR364640, CR364643, CR364849), that documented containment vacuum pump failures which occurred January 2-12, 2010. The containment vacuum pumps are part of a LSS system in standby that consists of two trains that maintain a vacuum in containment while the Unit is in operating mode. The containment vacuum pumps failures were not considered functional failures because the failures did not meet the licensees new criteria of a loss of both trains of containment vacuum with a plant demand for control. The criteria were changed from two MPFF per train and was reviewed and approved by the licensees MR expert panel on January 27, 2010.

Based on the new criteria the failures of the containment vacuum pumps in January 2010 did not require a functional failure review or an analysis of the failures.

The inspectors interviewed personnel to determine how the new criteria was in compliance with ER-AA-MRL-100 which states Availability or reliability performance criteria for trains or instruments channels monitored with overall system performance shall be such that masking poor performance of one train or instrument channel will be detected and addressed. The inspectors determined that the licensee did not have a full understanding of the procedural requirements.

Based on interviews and a review of the changes to the MR scoping matrix, the inspectors determined that the changes from train level to system level monitoring began in 2002 and continued through 2010. A review of the MR expert panel minutes showed that functions were being changed because the PRA updates changed the significance for a loss of train to LSS and High Safety Significant for loss of function.

The inspectors concluded that monitoring of MR a(2) HSS systems and LSS systems in standby with redundant trains could allow good performance of one train to mask the poor performance of another because functional failures were only counted for the loss of system function, or concurrent loss of multiple trains. The unavailability and reliability performance for multiple HSS trains and LSS trains in stand-by was not being monitored at the train level which does not ensure poor performing equipment is detected, proper maintenance is performed and the equipment is capable of performing its function. This does not demonstrate the performance or condition of SSCs is being effectively controlled through performance of appropriate preventative maintenance. The licensee monitored HSS and LSS systems against criteria that allowed masking of poor equipment performance and would prevent a system that should be in a(1) from being detected.

The licensees current MR program for several HSS systems and multiple LSS systems listed below do not address the masking of poor equipment performance for systems with redundant trains.

• Auxiliary Feedwater (provides minimum auxiliary feedwater (AFW) flow during a line break)

• Component Cooling (CC) (cooling water for charging pumps, reactor coolant pump thermal barrier coolers, residual heat removal system)

• Safety Injection (SI) (high head safety injection pumps)

• Condensate (provides make-up to emergency condensate System)

• Ventilation (provides chilled water for emergency switch Gear rooms)

• Turbine building sump (pumps liquid from the turbine building sump pumps)

• Containment vacuum pumps (maintains a containment vacuum during power operation)

• Refueling Water Storage Tank (RWST) Chillers

• Circulating Water (high level screens)

• Instrument Air Compressors The licensee has adjusted some of their HSS system reliability criteria specifically component cooling and safety injection and corrective actions have been initiated to address additional changes that were required.

Analysis:

The inspectors determined the licensees MR program could not demonstrate that reliability of High Safety Significant (HSS) systems and Low Safety Significant (LSS) systems in stand-by were being effectively controlled through the performance of appropriate preventative maintenance, such that the systems or components remain capable of performing their function is a performance deficiency.

Specifically, the monitoring established by the license did not effectively demonstrate that systems in a(2) were being effectively controlled through performance of appropriate preventative maintenance. This masking of poor equipment performance does not allow the licensee to determine if a system should be in increased monitoring of a(1).

The finding was more than minor because it adversely affected the equipment performance attribute of the reactor safety mitigating systems cornerstone, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of HSS and LSS systems to perform their functions when required.

Specifically, multiple HSS and LSS systems could have a high probability of failure, because poor equipment performance would not be recognized by the licensee. This could prevent a poor performing system from being placed into the a(1) category when required and appropriate corrective action would not be taken.

The finding was evaluated using MC-0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, and determined to be of very low safety significance (Green), because the finding did not involve an actual failure of equipment.

This finding had a cross-cutting aspect in the area of human performance and resources because the licensee did not ensure that personnel, procedures, and other resources were available and adequate to assure proper implementation of MR program. The MR personnel did not have the training required to implement the program within the required industry regulations and guidelines (H.2.b).

Enforcement:

10 CFR 50.65(a)(1), requires, in part, that the licensee monitor the performance or condition of SSCs within the scope of the rule as defined by 10 CFR 50.65(b), against licensee-established goals, in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions. 10 CFR 50.65(a)(2) states, in part, that monitoring as specified in 10 CFR 50.65(a)(1) was not required where it had been demonstrated that the performance or condition of an SSC was being effectively controlled through the performance of appropriate preventive maintenance, such that the SSC remained capable of performing its intended function.

Contrary to the above, the licensee failed to demonstrate that the performance or condition of systems required to be available during plant operation and within the scope of the rule had been effectively controlled through the performance of appropriate preventive maintenance and demonstrated that the SSCs remained capable of performing their function. Specifically, the licensees MR program could allow systems that should be in a(1) to remain in a(2) because poor equipment performance was being masked due to the licensees failure to monitor the reliability of HSS systems and LSS systems in standby at the train level. This failure is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy and is identified as NCV 05000280, 281/2010003-01: Failure to demonstrate that the reliability of systems or components were effectively controlled per 10 CFR 50.65 (a)(2).

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors evaluated, as appropriate, for the six work activities listed below: (1)the effectiveness of the risk assessments performed before maintenance activities were conducted;

(2) the management of 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. The inspectors verified that the licensee was complying 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. The inspectors reviewed the corrective action program to verify deficiencies in risk assessments were being identified and properly resolved.

• On-line green risk condition for Units 1 and 2 during rigging and lifting activities in the vicinity of the component cooling water pumps on May 11, 2010

• On-line red risk condition for Units 1 and 2 due to the emergent failure of the door to the common emergency switchgear room on May 11, 2010

• On-line yellow risk condition for Units 1 and 2 during planned repairs to the door to the common emergency switchgear room on May 10, 2010

• On-line green risk condition for Units 1 and 2 during maintenance to the Unit 2 B containment spray pump while the Unit 2 B condenser waterbox was out of service on April 29, 2010

• On-line green risk condition for Units 1 and 2 during an emergent failure of the alternate A/C diesel generator during planned surveillance testing of the low head safety injection system on April 23, 2010

• On-line green risk condition for Units 1 and 2 due to emergent maintenance to the

1. 2 EDG following its failure to run during 2-OPT-EG-001 on April 19, 2010

b. Findings

Introduction:

A self-revealing Green Finding was identified for the failure to adequately rig a 300 pound motor in the auxiliary building in accordance with the manufacturers recommendations on May 11, 2010. As a result, the motor slipped from its rigging and dropped approximately 15 feet onto the A component cooling water (CCW) pump motor below, damaging the motors cabling and electrical junction box. The CCW pump was declared inoperable (CR 380834), the damage was repaired, and the CCW pump restored to an operable status on May 15, 2010.

Description:

On May 11, 2010, riggers in the Auxiliary Building were lifting a 300 pound contaminated boron recovery pump motor from the minus two foot elevation to the 13 foot elevation. The motor was wrapped in plastic to prevent the spread of contamination. During the pre-job brief the team discussed the planned evolution, concerns involved with the lift, and sensitive equipment in the area. The plastic wrapping was identified as a rigging concern because of its slippery surface. The motor was rigged in a choked configuration with two one inch nylon straps around the motor and the hand truck it was resting on. The motor and the hand truck were not independently secured together. A test lift of less than one foot was performed and deemed satisfactory. The load was then lifted vertically to the 13 foot elevation without incident. However, as the team attempted to reposition the load and maneuver it horizontally over the hand rail on the 13 foot elevation, the motor slipped out from its rigging and dropped approximately 15 feet onto the A CCW pump motor below. The dropped motor impacted the CCW pump motor casing and damaged the motors electrical junction box and associated electrical cables. The pump was declared inoperable due to the damage to the electrical box and cables.

The preferred method of rigging small motors outfitted with a threaded connection for a lifting eyebolt is to install the lifting eyebolt and rig from that point. This is mentioned in the vendor technical manual, 38-W893-00027, Revision 6, AC Motors Frames 143-449 where it says, Lifting eyebolts are designed for lifting the motor alone and should be removed after installation. The vendor manual recommendations are incorporated into MA-AA-101, Revision 5, Fleet Lifting and Material Handling by step 3.2.4.a which reads, Use rigging in accordance with the guidance contained in manufacturer recommendations. The boron recovery motor had a threaded connection for a lifting eyebolt and the rigging team attempted to get the plastic wrapping removed so an eyebolt could be used, but was unsuccessful due to communication errors with the HP tech. The rigging team decided at this point that a choked configuration could be used instead and did not further pursue the eyebolt method. Due to the fact that the fleet lifting and material handling procedure is information use, meaning it is not required to be checked off step by step or brought into the field and also because the riggers had performed hundreds of lifts under the procedure in the past, there was no process in place to ensure that the important steps in the procedure would be evaluated for every lift, e.g., verification of manufacturer recommendations and Maintenance Rule a(4) risk notifications when lifting near risk significant equipment. Also, the area of the Auxiliary Building in the vicinity of the Component Cooling Water Pumps was not designated as a sensitive lifting area where damage to risk significant equipment could occur. As a result of this event, a checklist has been developed and is being used for every lift to ensure that decisions which deviate from the preferred rigging methods are properly understood and approved.

Analysis:

Inspectors determined that the failure to implement adequate rigging practices in accordance with vendor recommendations as required by procedure MA-AA-101, Revision 5, Fleet Lifting and Material Handling constituted a performance deficiency and a finding which was reasonably within the licensees ability to foresee and correct and which should have been prevented. The finding is similar to MC 0612, Appendix E example 4.f, and is more than minor because it resulted in damage to and inoperability of a risk significant component. The finding is associated with the human performance attribute of the initiating events cornerstone and adversely affected the cornerstone objective to limit the likelihood of those events which upset plant stability and challenge critical safety functions during shutdown as well as power operations because a loss of the component cooling water system would have resulted in a unit transient. The finding, evaluated per Attachment 4 of MC-0609, Phase 1 - Initial Screening and Characterization of Findings, was determined to be of very low safety significance (Green) because it did not contribute to both the likelihood of a plant transient and the loss of accident mitigation equipment. This finding has a cross-cutting aspect in the area of human performance, decision making because the licensee did not make safety/risk significant decisions using a systematic process, especially when faced with uncertain decisions, to ensure safety is maintained (H.1(a)). Specifically, the rigging team made risk significant decisions within lifting/rigging procedures that did not include a systematic process for evaluating each lift, especially loads <5000 lbs in the vicinity of risk significant equipment.

Enforcement:

Enforcement action does not apply because the performance deficiency did not involve a violation of a regulatory requirement. Because this finding does not involve a violation of regulatory requirements, has very low safety significance, and has been entered into the licensees CAP as CR 380834, it is identified as: FIN 05000280/2010003-02: Inadequate rigging practices result in damage to risk significant equipment.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the five operability evaluations 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;

(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 Conditions for Operation and the risk significance. The inspectors review included verification that determinations of operability followed procedural requirements of OP-AA-102, Operability Determination. The inspectors reviewed the corrective action program to verify deficiencies in operability determinations were being identified and corrected.

• CR 376089, Unit 2 A battery cell 43 degrading trend identified

• CR 381346, Unit 1 C main steam line snubber found with low oil level

• CR 380817, Unit 1 A battery cell 51 crack in cover identified by NRC

• CR 380846, Units 1 and 2 packing leak on emergency service water pump B

• CR 376923; Units 1 and 2 containment sump strainer module fasteners

b. Findings

No findings were identified.

1R19 Post Maintenance Testing

a. Inspection Scope

For the eight risk-significant maintenance activities listed below, the inspectors reviewed the associated post maintenance testing (PMT) procedures and either witnessed the testing and/or reviewed completed records 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)test 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) test 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 reviewed the corrective action program to verify PMT deficiencies were being identified and corrected. Documents reviewed are listed in the attachment to this report.

• Preventive maintenance on circuit breaker 2-EP-BKR-24H-5 for containment spray pump, 2-CS-P-1A, W.O. 38102153533 and 38102573543

• Preventive maintenance on circuit breaker 2-EP-BKR-24J-5 for containment spray pump, 2-CS-P-1B, WO. 38102760534 and 38102153547

• Preventive maintenance on containment spray pump, 1-CS-P-1B, W.O.

38102106699

• Preventive maintenance on containment spray motor operated valve 01-CS-MOV-100B, W.O. 38102120858

• Corrective maintenance on #2 EDG following a start failure on April 19, W.O.

38102521373, 38102778588, and 38102778637

• Corrective maintenance on #1 EDG following a start failure on March 29, W.O.

38102770754, 38102770575, 38177164801, 38102770743, and 3810202770864

• Preventative maintenance to low head safety injection pump 1-SI-P-1B, W.O 38102405582

• Preventative maintenance to charging component cooling water pump 2-CC-P-2A, W.O. 38079138101, 38102124561

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

.1 New Fuel Receipt Inspections

a. Inspection Scope

The inspectors observed new fuel receipt and inspection to verify fuel handling operations were being performed in accordance with technical specifications and approved procedures. Included in the inspection was verification that the security seal on the shipping containers was intact, the shipping containers accelerometers were not tripped, the fuel assemblies were being properly tracked, and that personnel who performed the work were appropriately qualified.

b. Findings

No findings were identified.

.2 Unit 1 Forced Outage

a. Inspection Scope

A forced outage was conducted from June 8 - 11, 2010, following the automatic trip and safety injection on June 8, 2010, and subsequent failure of two resistance-capacitor (RC) filters in the Unit 1 nuclear instrumentation cabinets. The inspectors observed evolutions to stabilize the unit in an Intermediate Shutdown Mode, a hot condition (i.e. > 200°F) 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 inspector.

Evolutions to startup and place the Unit on-line were observed by the inspectors. No work was performed in containment during the forced outage.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors witnessed and/or reviewed test records for the six risk-significant surveillance tests listed below, to determine whether the SSCs selected meet Technical Specifications (TS), the Updated Final Safety Analysis Report (UFSAR),and licensees procedure requirements and demonstrate that the SSCs are capable of performing their intended safety functions (under conditions as close as practical to accident conditions or as required by TS) and their operational readiness.

In-Service Testing:

• 1-OPT-CS-006, Rev. 9, Unit 1 RWST, Chemical Injection Tank, and Containment Spray System MOV Stroke Test

• 1-OPT-CS-002, Rev 15; Containment Spray System Test

• 2-OPT-CS-002, Rev 13; Containment Spray System Test Surveillance Testing:

• 0-OPT-FP-009, Rev 18; Diesel Driven Fire Protection Pump Test

• 0-OPT-VS-002, Rev 28; Auxiliary Ventilation Filter Train Test

• 2-EPT-0109-01, Rev 15; Station Battery 2A Pilot Cell and Bus Voltage Checks

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors observed the emergency response combined functional exercise conducted on May 5, 2010. Inspection focused on assessment of licensee performance in event classification, protective action recommendations, and off-site notifications in accordance with the Surry Emergency Plan. The drill required emergency plan response actions be taken by personnel located in the simulator control room, the technical support center (TSC), the local and corporate emergency operating facilities (LEOF, CEOF) and the joint news information center. The inspectors observed conduct of the drill in-part from the simulator control room and TSC. The inspectors reviewed CR 380024 which documented two missed notification opportunities during the drill. This drill is included in the Emergency Response Performance Indicator Statistics.

b. Findings

No findings were identified.

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

The inspectors performed a periodic review of the following Unit 1 and 2 performance indicators (PI) 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.

Specifically, the inspectors reviewed the PI data for the second quarter 2009 through the first quarter 2010. Documents reviewed included licensee even reports (LERs),operator and chemistry department logs, and NRC inspection reports.

Mitigating Systems Cornerstone

• Safety System Functional Failures (SSFF)

Barrier Integrity Cornerstone

• Reactor Coolant System Specific Activity

• Reactor Coolant System Leak Rate

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

.1 Daily Reviews 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 Operator Work Arounds

a. Inspection Scope

The inspectors performed an in-depth review of operator workarounds (OWAs) to verify they were being identified at an appropriate threshold and entered into the corrective action program. Inspection focused on identification of risk significant workarounds on mitigating systems. Workarounds were reviewed and assessed for the impact on the systems ability to perform its safety function(s) and the operators ability to implement abnormal and emergency operating procedures and respond in a correct and timely manner to plant transients and accidents. Potential impacts on multiple mitigating systems were considered and the cumulative effect on system reliability and availability, as well as potential for miss operation, was reviewed.

Workarounds, formalized as long-term corrective action for a degraded or non-conforming condition, were sought out with particular attention given to identifying workarounds that increased the potential for personnel error, or:

• require operations contrary to past training

• require more detailed knowledge of systems 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

• 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 The inspection was accomplished by document reviews, plant tours, and interviews with licensed and non-licensed operators.

b. Findings and Observations

No findings were identified. The inspectors noted however, the operator workaround in place to isolate the Unit 1 leaking pressurizer power operated relief valve (PORV)had not been entered in the licensees program. A second work around, which had been classified as a control room deficiency, has languished since May 2008 due to obsolescence issues with the failed component. The need to obtain steam release radiation readings locally rather than from the plant computer system slowed the operator response to the June 8th reactor trip and safety injection, contributing to additional cycling of the pressurizer PORV.

.3 Annual Sample: CR 374758 Increased Frequency of Nitrogen Addition to Unit 2 B

Safety Injection Accumulator

a. Inspection Scope

The inspectors selected CR 374758 and its associated corrective actions for follow-up based on the safety significance of the passive safety injection accumulators and the potential impact on the licensees ability to meet the technical specification requirements. The inspectors reviewed the CR and CAs against the applicable performance attributes contained in NRC inspection procedure 71152, Problem Identification and Resolution.

b. Findings and Observations

No findings were identified.

.4 Semi-Annual Review to Identify Trends

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 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; self-assessment reports, control room status logs, and lists of control room deficiencies. The inspectors review nominally considered the six-month period of January 1, 2010 through June 28, 2010.

b. Findings and Observations

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

4OA3 Event Follow-up

June 8, Reactor trip and Safety Injection The inspectors responded to the main control room immediately following the reactor trip and safety injection that occurred on June 8, 2010, at 09:48. The inspectors observed the operating crews response to the event and assessed crew performance with respect to command and control, communications, task prioritization, and the execution of alarm response procedures, abnormal and emergency operating procedures, and the implementation of the Surry Emergency Plan. Details of the event and any associated inspection findings will be provided in the NRC Special Inspection Team (SIT) inspection report, IR 05000280/2010006.

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 Independent Spent Fuel Storage Installation (ISFSI) Inspections (IP 60855.1)

a. Inspection Scope

The inspectors reviewed reported changes made to the licensees procedures and programs for the Independent Spent Fuel Storage Installation (ISFSI) to verify the changes made were consistent with the license and Certificate of Compliance (CoC),and did not reduce the effectiveness of the program. The inspectors, through direct observation and independent evaluation, verified cask loading activities were performed in a safe manner and in compliance with approved procedures. Based on direct observation and review of selected records, the inspectors verified the licensee had properly identified each fuel assembly and insert placed in the ISFSI, had recoded the parameters and characteristics of each fuel assembly and insert, and had maintained a record of each as a controlled document. Inspection activities were associated with casks DOM-32PTH-018-C, DOM-32PTH-023-C, and DOM-32PTH-024-C. Activities observed include: transport and storage of cask DOM-32PTH-024-C, loading of spent fuel in cask DOM-32PTH-023-C, drying and seal welding activities on DOM-32PTH-018-C, and the heavy lift to remove DOM-32PTH-023-C from the spent fuel pool.

The inspectors reviewed the design limitations for each Dry Shielded Cask (DSC) and compared the specified cask loading to the casks loading limitations and Technical Specification requirements. The inspectors verified limitations for heavy load lifts in and around the spent fuel pool were incorporated into the licensees procedures and adhered to.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On July 21, 2010 the inspection results were presented to Mr. Bischoff and other members of his 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.

ATTACHMENT: SUPPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Adams, Director, Station Engineering

G. Bischof, Site Vice President

J. Eggart, Manager, Radiation Protection & Chemistry

B. Garber, Supervisor, Licensing

D. Godwin, Supervisor, Nuclear Engineering

K. Grover, Manager, Operations

A. Harrow, Supervisor, Electrical Systems

B. Hilt, Supervisor, HP Technical Services

R. Johnson, Manager, Outage and Planning

R. Manrique, Supervisor, Primary Systems

C. Olsen, Manager, Site Engineering

L. Ragland, Supervisor, Health Physics Operations

K. Sloane, Plant Manager (Nuclear)

B. Stanley, Director, Station Safety and Licensing

D. White, Supervisor, ALARA

M. Wilda, Supervisor, Auxiliary Systems

LIST OF ITEMS

Opened and Closed

05000280, 281/2010003-01 NCV Failure to demonstrate that the reliability of systems or components were effectively controlled per 10 CFR 50.65 (a)(2) (1R12)

05000280/2010003-02 FIN Inadequate rigging practices result in damage to risk significant equipment (1R13)