IR 05000280/2011008

IR 05000280-11-008 and 05000281-11-008; on 06/6/2011 06/24/2011; Surry Power Station, Units 1 and 2; Biennial Inspection of Problem Identification and Resolution Program

ML112030170
Person / Time
Site:	Surry
Issue date:	07/22/2011
From:	Hopper G Reactor Projects Branch 7
To:	Heacock D Virginia Electric & Power Co (VEPCO)
References
IR-11-008
Download: ML112030170 (18)

Text

UNITED STATES uly 22, 2011

SUBJECT:

SURRY POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000280/2011008 AND 05000281/2011008

Dear Mr. Heacock:

On June 24, 2011, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Surry Power Station Units 1 and 2. The enclosed report documents the inspection findings, which were discussed on June 24, 2011, with other members of your staff.

The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of plant equipment and activities, and interviews with personnel.

On the basis of the samples selected for review, there were no findings identified during this inspection. The inspectors concluded that problems were properly identified, evaluated, and resolved within the corrective action program (CAP). However, during the inspection, two minor issues were identified related to your identification of issues and the effectiveness of the corrective action program.

CP&L 2 In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure 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 Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

George T. Hopper, Chief Reactor Projects Branch 7 Division of Reactor Projects Docket Nos.: 50-280, 50-281 License Nos.: DPR-32, DPR-37

Enclosure:

Inspection Report 05000280/2011008 and 05000281/2011008 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-280, 50-281 License Nos.: DPR-32, DPR-37 Report No.: 05000280/2011008 and 05000281/2011008 Licensee: Virginia Electric and Power Company (VEPCO)

Facility: Surry Power Station, Units 1 and 2 Location: 5850 Hog Island Rd Surry, VA 23883 Dates: June 6 - 10, 2011 June 20 - 24, 2011 Inspectors: N. Staples, Senior Project Inspector, Team Leader R. Taylor, Senior Project Inspector S. Subosits, Senior Resident Inspector, B&W NOG J. Nadel, Resident Inspector, Surry Approved by: G. Hopper, Chief, Reactor Projects Branch 7 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000280/2011008, 05000281/2011008; 06/6/2011 - 06/24/2011; Surry Power Station, Units and 2; Biennial Inspection of Problem Identification and Resolution Program.

The inspection was conducted by two senior project inspectors, a senior resident inspector and a resident inspector. No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Identification and Resolution of Problems The inspection team concluded that, in general, problems were adequately identified, prioritized, and evaluated; and effective corrective actions were implemented. Site management was actively involved in the corrective action program (CAP) and focused appropriate attention on significant plant issues. The team found that employees were encouraged by management to initiate condition reports (CRs) as appropriate to address plant issues.

The licensee was effective at identifying problems and entering them into the CAP for resolution, as evidenced by the relatively few deficiencies identified by the NRC that had not been previously identified by the licensee during the review period. The threshold for initiating CRs was appropriately low, as evidenced by the type of problems identified and large number of CRs entered annually into the CAP. In addition, CRs normally provided complete and accurate characterization of the problem.

Generally, prioritization and evaluation of issues were adequate and consistent with the licensees CAP guidance. Formal root cause evaluations for significant problems were adequate, and corrective actions specified for problems did address the cause of the problems.

The age and extensions for completing evaluations were closely monitored by plant management, both for high priority condition reports, as well as for adverse conditions of less significant priority. Also, the technical adequacy and depth of evaluations (e.g., root cause investigations) were typically adequate. However, the team identified two minor issues associated with the licensees identification of issues and effectiveness of corrective actions.

Corrective actions were generally effective, timely, and commensurate with the safety significance of the issues.

The operating experience program was effective in screening operating experience for applicability to the plant, entering items determined to be applicable into the CAP, and taking adequate corrective actions to address the issues. External and internal operating experience was adequately utilized and considered as part of formal root cause evaluations for supporting the development of lessons learned and corrective actions for CAP issues.

The licensees audits and self-assessments were critical and effective in identifying issues and entering them into the corrective action program. These audits and assessments identified issues similar to those identified by the NRC with respect to the effectiveness of the CAP.

Based on general discussions with licensee employees during the inspection, targeted interviews with plant personnel, and reviews of selected employee concerns records, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP as well as the employee concerns program to resolve those concerns.

REPORT DETAILS

4OA2 Problem Identification and Resolution

a. Assessment of the Corrective Action Program

(1) Inspection Scope The inspectors reviewed the licensees corrective action program (CAP) procedures which described the administrative process for initiating and resolving problems primarily through the use of condition reports (CRs). To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the inspectors reviewed CRs that had been issued between June 2009 and May 2011 including a detailed review of selected CRs associated with the following risk-significant systems:

Service Water (SW), Safety Injection (SI), Emergency Diesel Generators (EDGs), and Alternate AC Power (AAC). Where possible, the inspectors independently verified that the corrective actions were implemented as intended. The inspectors also reviewed selected common causes and generic concerns associated with root cause evaluations to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the NRCs Reactor Oversight Process (ROP), the inspectors selected a representative number of CRs that were identified and assigned to the major plant departments, including operations, maintenance, engineering, health physics, chemistry, and security. These CRs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The inspectors reviewed selected CRs, verified corrective actions were implemented, and attended meetings where CRs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.

The inspectors conducted plant walkdowns of equipment associated with the selected systems and other plant areas to assess the material condition and to look for any deficiencies that had not been previously entered into the CAP. The inspectors reviewed CRs, maintenance history, completed work orders (WOs)/work requests (WRs)for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period of time; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-dependent issues.

Main control room (MCR) walkdowns were also performed to assess the MCR deficiency list and to ascertain if deficiencies were entered into the CAP. Operator Workarounds and Operator Burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the field.

The inspectors conducted a detailed review of selected CRs to assess the adequacy of the root cause and apparent cause evaluations of the problems identified. The inspectors reviewed these evaluations against the descriptions of the problem described in the CRs and the guidance in licensee procedures PI-AA-300-3001, Root Cause Evaluation, and PI-AA-300-3002, Apparent Cause Evaluation. The inspectors assessed if the licensee had adequately determined the cause(s) of identified problems, and had adequately addressed operability, reportability, common cause, generic concerns, extent-of-condition, and extent-of-cause. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence where applicable.

The inspectors reviewed selected industry operating experience items, including NRC generic communications to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP.

The inspectors reviewed site trend reports to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.

The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included CR Review Team (CRT)meetings and Corrective Action Review Board (CARB) meetings.

Documents reviewed are listed in the Attachment.

(2) Assessment Identification of Issues The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was a low threshold for entering issues into the CAP. This conclusion was based on the type of problems entered into the CAP; the review of licensee requirements for initiating CRs as described in licensee procedure ADM-PI-AA-200, Corrective Action; the management expectation that employees were encouraged to initiate CRs for any issue that is not meeting performance expectations regardless of whether it is a potential, suspect, or actual problem; a review of system health reports; and on inspectors observations during plant walkdowns. Trending was generally effective in monitoring equipment performance.

Site management was actively involved in the CAP and focused appropriate attention on significant plant issues.

Based on reviews and walkdowns of accessible portions of the selected systems, the inspectors determined that system deficiencies were being identified and placed in the CAP.

The inspectors identified one issue that had not been identified in the CAP. This issue was screened in accordance with Manual Chapter 0612, Issue Screening, and determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.

• The inspectors identified a missed opportunity to identify that high jacket water alarm actuation did not occur. The team reviewed CR 387191 which documented an AAC Diesel over-temperature event that occurred in July 2010.

During the events only the high exhaust temperature alarmed, however several other parameters were above or near their procedural set points. The licensee reviewed the alarm set points for these parameters and agreed that the high jacket water temperature alarm should have also actuated with the documented jacket water outlet temperature of 213F and the alarm set point of 208F. The licensee generated CR 430338 to address this issue.

Prioritization and Evaluation of Issues Based on the review of CRs sampled by the inspection team during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in the CR severity level determination guidance in ADM-PI-AA-200, Corrective Action. Each CR was assigned a severity level at the CRT meetings, and adequate consideration was given to system or component operability and associated plant risk.

The inspectors determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures and assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of causal-analysis techniques were used depending on the type and complexity of the issue consistent with licensee procedures PI-AA-300, Cause Evaluation; PI-AA-300-3001, Root Cause Evaluation; PI-AA-300-3002, Apparent Cause Evaluation; PI-AA-300-3003, Common Cause Evaluation; and PI-AA-300-3004, Cause Evaluation Methods. The inspectors determined that the licensee had performed evaluations that were technically accurate and of sufficient depth.

Effectiveness of Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected and non-recurring. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, CRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.

The inspectors identified one performance deficiency associated with the licensees effectiveness of corrective actions. This issue was screened in accordance with Manual Chapter 0612, Issue Screening, and determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.

• During a review of the licensees corrective actions for Apparent Cause Evaluation, (ACEs) 018142 and 018454 the inspectors found an instance where a repeat event was weakly evaluated. Three CRs (350580, 378102, and 403870)documented that AAC starting air compressor safety valve failed open and the licensee documented different causes for the failure of the valve. During the process of performing ACE 018142 and 018454, the licensee was required to do an assessment of previous CRs in accordance with procedure PI-AA-300-3002, Apparent Cause Evaluation, to determine if any repeats where previously identified and evaluated. The procedure defines a repeat event as a previously identified condition (failure, problem, or deficiency) that was investigated, had corrective actions developed, but recurred due to failure to implement the corrective action or ineffective corrective actions. Each CR (350580, 378102, and 403870) documented that the starting air compressor safety valve failed open, but different failure causes were identified, therefore the licensee determined that a repeat failure had not recurred. The inspectors determined that this event was a repeat because the licensee had investigated the issue, developed and implemented corrective actions and the failure recurred. The inspectors determined that the licensee did perform the ACE evaluation for repeat assessment of previous CRs, but the licensee missed an opportunity to assess the failure of the valve in accordance with procedure PI-AA-300-3002. The licensee generated CR 432114 to address this issue.

(3) Findings No findings of significance were identified.

b. Assessment of the Use of Operating Experience (OE)

(1) Inspection Scope The inspectors examined licensee programs for reviewing industry operating experience, reviewed licensee procedure PI-AA-100-1007, Operating Experience Program, and reviewed the licensees operating experience database to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the inspectors selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal operating experience items, etc.), which had been issued since May 2009 to verify whether the licensee had appropriately evaluated each notification for applicability to the Surry plant, and whether issues identified through these reviews were entered into the CAP. Procedure PI-AA-100-1007, "Operating Experience Program,"

was reviewed to verify that the requirements delineated in the program were being implemented at the station. Documents reviewed are listed in the Attachment.

(2) Assessment Based on a review of documentation related to the review of operating experience issues, the inspectors determined that the licensee was generally effective in screening operating experience for applicability to the plant. Industry OE was evaluated by plant OE Coordinators and relevant information was then forwarded to the applicable department for further action or informational purposes. OE issues requiring action were entered into the CAP for tracking and closure. In addition, operating experience was included in all root cause evaluations in accordance with licensee procedure PI-AA-300, Cause Evaluation, PI-AA-300-3001, Root Cause Evaluation, and PI-AA-300-3002, Apparent Cause Evaluation.

(3) Findings No findings were identified.

c. Assessment of Self-Assessments and Audits

(1) Inspection Scope The inspectors reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self assessments. The inspectors also verified that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedures PI-AA-100-1004, Formal Self-Assessments and PI-AA-100-1005, Informal Self-Assessments.

(2) Assessment The inspectors determined that the scopes of assessments and audits were adequate.

Self-assessments were generally detailed and critical, as evidenced by findings consistent with the inspectors independent review. The inspectors verified that CRs were created to document all areas for improvement and findings resulting from the self-assessments, and verified that actions had been completed consistent with those recommendations. Generally, the licensee performed evaluations that were technically accurate. Site trend reports were thorough and a low threshold was established for evaluation of potential trends, as evidenced by the CRs reviewed that identified adverse trends.

(3) Findings No findings were identified.

d. Assessment of Safety-Conscious Work Environment

(1) Inspection Scope The inspectors randomly interviewed 14 on-site workers regarding their knowledge of the corrective action program at Surry and their willingness to write CRs or raise safety concerns. During technical discussions with members of the plant staff, the inspectors conducted interviews to develop a general perspective of the safety-conscious work environment at the site. The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns.

The inspectors reviewed the licensees Employee Concerns Program (ECP) and interviewed the ECP manager. Additionally, the inspectors reviewed a sample of ECP issues to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.

(2) Assessment Based on the interviews conducted and the CRs reviewed, the inspectors determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees.

Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.

(3) Findings No findings were identified.

4OA6 Meetings, Including Exit

On June 24, 2011, the inspectors presented the inspection results to Mr. M. Adams and other members of the site staff. The inspectors confirmed that all proprietary information examined during the inspection had been returned to the licensee.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

B. Belcher, ECP Coordinator

G. Bischof, Site Vice President

M. Adams, Director of Engineering

A. Harrow, Manager Organizational Effectiveness

J. Rosenberger, Manager Engineering Programs

J. Ashley, Licensing Engineering

B. Garber, Licensing Supervisor

D. Herring, Supervisor Nuclear Engineering

J. Holloway, Supervisor Engineering Coordination

T. Sadler, Corrective Action Coordination

NRC

J. Nadel, Resident Inspector

G. Hopper, Chief, Branch 7, Division of Reactor Projects

LIST OF REPORT ITEMS

Opened and Closed

None

Closed

None

Discussed

None