IR 05000280/2013007

IR 05000280-13-007, 05000281-13-007; 07/8/2013 - 07/25/2013; Surry Power Station, Units 1 and 2; Biennial Inspection of Problem Identification and Resolution Program

ML13232A175
Person / Time
Site:	Surry
Issue date:	08/20/2013
From:	Manuel Crespo Reactor Projects Branch 7
To:	Heacock D Virginia Electric & Power Co (VEPCO)
References
IR-13-007
Download: ML13232A175 (17)

Text

UNITED STATES ust 20, 2013

SUBJECT:

SURRY POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000280/2013007 AND 05000281/2013007

Dear Mr. Heacock:

On July 25, 2013, the U. S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution biennial inspection at your Surry Power Station Units 1 and 2. The enclosed report documents the inspection results which were discussed on July 25, 2013, with other members of your staff.

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

Based on the inspection sample, the inspection team concluded that the implementation of the corrective action program and overall performance related to identifying, evaluating, and resolving problems at Surry Power Station Units 1 and 2 was adequate. Licensee identified problems were entered into the corrective action program at a low threshold. Problems were generally prioritized and evaluated commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner. Corrective actions were generally implemented in a timely manner commensurate with their importance to safety and addressed the identified causes of problems. Lessons learned from industry operating experience were effectively reviewed and applied when appropriate. Audits and self-assessments were effectively used to identify problems and appropriate actions.

No findings were identified during this inspection. 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/

Manuel Crespo, Chief (Acting)

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

Enclosure:

Inspection Report 05000280/2013007 and 05000281/2013007 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-280, 50-281 License Nos.: DPR-32, DPR-37 Report No.: 05000280/2013007 and 05000281/2013007 Licensee: Virginia Electric and Power Company Facility: Surry Power Station, Units 1 and 2 Location: 5850 Hog Island Rd Surry, VA 23883 Dates: July 8 - 12, 2013 July 22 - 25, 2013 Inspectors: C. Fletcher, Senior Reactor Inspector (Team Leader)

E. Coffman, Resident Inspector (Virgil C. Summer Nuclear Station)

B. Collins, Reactor Inspector K. Cotton, Surry Project Manager (HQ)

A. Sengupta, Reactor Inspector Approved by: M. Crespo, Chief (Acting),

Reactor Projects Branch 7 Division of Reactor Projects Enclosure

SUMMARY

IR 05000280/2013007, 05000281/2013007; 07/8/2013 - 07/25/2013; Surry Power Station, Units and 2; Biennial Inspection of Problem Identification and Resolution Program.

The inspection was conducted by one senior reactor inspector, two reactor inspectors, one project manager, and a resident inspector (Virgil C. Summer Nuclear Station). 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.

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 2011 and July 2013 including a detailed review of selected CRs associated with the following risk-significant systems:

Service Water, Ventilation, Emergency Diesel Generators (EDGs), and Electrical Power.

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, the inspectors selected a representative number of CRs that were identified and assigned to the major plant departments, including operations, engineering, health physics, emergency preparedness, 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/work requests 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 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 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.

However, 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 that a 10 CFR Part 21 screening was not performed for a #2 EDG air start relay failure occurring on January 21, 2013, requiring a manual swap to the other air start train in order to manually start the #2 EDG.

Specifically, a substantial safety hazard evaluation was not performed by the technical lead as required by the licensees procedure LI-AA-301, Implementation of 10 CFR 21, Reporting of Defects and Noncompliance, Revision 0. Further, the relays failure analysis was completed on June 7, 2013 by the relays manufacturer, but the relay was not evaluated for Part 21 applicability by the manufacturer or the licensee. LI-AA-301 requires in part that the licensee determine within 45 days whether a defect or noncompliance is potentially reportable in accordance with 10 CFR Part 21. Had the manufacturer identified a defect, this 45 day limit would not have been met. In addition, the licensee later determined that the manufacturer did not currently have an approved 10 CFR 50 Appendix B quality assurance program, and that the relay should have been sent to the vendor that provided the relay. This issue was documented in the licensees CAP as CR 5215757.

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 procedure as described in the CR severity level determination guidance in ADM-PI-AA-200, Corrective Action. The inspectors determined that overall, each CR was assigned an adequate severity level at the CRT meetings, and adequate consideration was given to system or component operability and associated plant risk.

However, the inspectors identified a potential weakness in the licensees CAP Procedure, PI-AA-200, Attachment 4. 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 weakness in the licensees CAP Procedure, PI-AA-200, Attachment 4, in the CR significance screening row for Equipment Issues and the screening column for CR Significance Level 2. Specifically, the licensee uses Abnormal failure frequency of equipment important to safety or reliability as one of the screening criteria to differentiate between a CR significance level 2 and a level 3 issue. The inspectors identified that Abnormal failure frequency is not clearly defined by the licensees CAP procedure and found several examples where subjectivity could allow deficient conditions to exist for long periods of time, specifically when these conditions have already been identified on a repetitive basis. While the licensee took corrective actions to address the conditions identified, the licensees CAP procedure did not provide clear guidance when repetitive CRs should prompt a more thorough review of the issue (e.g. escalate the issue from CR significance level 3 to level 2) to aide in establishing measures to promptly correct conditions adverse to quality.

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. 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 were sufficient to ensure corrective actions were properly implemented and were effective.

(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 8 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 July 25, 2013, the inspectors presented the inspection results to Mr. D. Lawrence 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

G. Bischof, Site Vice President

D. Lawrence, Director of Nuclear Safety and Licensing

A. Harrow, Manager Organizational Effectiveness

J. Rosenberger, Manager Engineering Programs

J. Pollard, Licensing Engineering

B. Garber, Licensing Supervisor

D. Herring, Supervisor Nuclear Engineering

J. Holloway, Supervisor Engineering Coordination

T. Sadler, Corrective Action Coordinator

W. Belcher, ECP Coordinator

C. Bruce, Supervisor Mechanical and Civil Design Engineering

NRC

J. Nadel, Resident Inspector

R. Cureton, Senior Resident Inspector

LIST OF REPORT ITEMS

Opened and Closed

None

Closed

None

Discussed

None