IR 05000280/2020001

Integrated Inspection Report 05000280/2020001 and 05000281/2020001; and 07200055/2020001

ML20129J824
Person / Time
Site:	Surry, 07200055
Issue date:	05/08/2020
From:	Stewart Bailey Division Reactor Projects II
To:	Stoddard D Virginia Electric & Power Co (VEPCO)
References
IR 2020001
Download: ML20129J824 (15)

Text

May 8, 2020

SUBJECT:

SURRY POWER STATION - INTEGRATED INSPECTION REPORT 05000280/2020001 AND 05000281/2020001; AND 07200055/2020001

Dear Mr. Stoddard:

On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Surry Power Station. On April 20, 2020, the NRC inspectors discussed the results of this inspection with Fred Mladen, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Stewart N. Bailey, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 05000280, 05000281 and 07200055 License Nos. DPR-32 and DPR-37

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000280 and 05000281; 07200055 License Numbers: DPR-32 and DPR-37 Report Numbers: 05000280/2020001, 05000281/2020001; and 07200055/2020001 Enterprise Identifier: I-2020-001-0066; I-2020-001-0112 Licensee: Virginia Electric and Power Company Facility: Surry Power Station Location: Surry , VA Inspection Dates: January 01, 2020 to March 31, 2020 Inspectors: L. McKown, Senior Resident Inspector C. Read, Resident Inspector S. Downey, Senior Reactor Inspector Approved By: Stewart N. Bailey, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Surry Power Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 operated at or near rated thermal power for the entire inspection period.

Unit 2 operated at or near rated thermal power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week during which they conducted plant status activities as described in IMC 2515, Appendix D, and observed risk significant activities when warranted. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In the cases where it was determined the objectives and requirements could not be performed remotely, management elected to reschedule the inspection to a later date.

71111.01 - Adverse Weather Protection

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather associated with snow and ice on February 13, 2020.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) 'B', 'C', and 'E' main control room (MCR) chillers and #1 and #2 emergency diesel generators during concurrent inoperability of 'A' and 'D' MCR chillers on January 15, 2020.

(2) Unit 1 and 2 containment gaseous and particulate radiation monitors on February 27, 2020.

(3) #2 and #3 emergency diesel generators during quarterly testing of the #1 emergency diesel generator on March 4, 2020.

(4) Unit 1 'A' reactor coolant pump loop via drone in motor cubicle on March 4, 2020.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Unit 1 main feedwater pump addition of air inlet filters creating potential for vacuum and misting of oil system inside motor enclosure, on January 6, 2020.

(2) Unit 1 and Unit 2 high pressure turbine enclosures following potential electrohydraulic control fluid seepage on Unit 2, on January 22, 2020.

(3) Unit 1 'A' reactor coolant pump motor cubicle while at power via drone footage, on March 4, 2020.

(4) Yard areas containing the buried fire protection loop following automatic start of the motor-driven and diesel-driven pumps on March 12, 2020.

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Component Cooling Heat Exchangers.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during Unit 1 degraded condenser vacuum resulting in abnormal procedure entry, Unit 1 'A' main feedwater pump motor soft foot adjustments, and Unit 2 containment entry for power operated relief valve operating air bottle checks on February 27, 2020.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a licensed operator requalification training scenario involving a steam generator tube rupture event followed by a safety injection with inadequate flow to the core, on February 5, 2020.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Component Cooling Heat Exchangers, inspection completed March 25, 2020.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed;

(1) Unit 1 risk associated with soft foot checks on the 1A1 main feedwater pump, on January 9, 2020.

(2) Unit 1 and Unit 2 risk increase when operators identified boric acid accumulations on backflow preventers in the Unit 1 'A' and 'C' charging pump cubicles, on January 28, 2020.

(3) Unit 2 risk associated with 2-PT-18.6I, pressurizer block valves stroke testing, with a known packing leak on one block valve, on February 14, 2020.

(4) Elevated risk associated with additional personnel inside the power block during station cleanup day, on February 18, 2020.

(5) Unit 1 risk associated with utilizing a drone for inspections in the 'A' reactor coolant pump motor cubicle while at power, on March 4, 2020.

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) CR1139136, Unit 2 main turbine stop valve electrohydraulic control fluid hoses sweating, on January 9, 2020.

(2) CR1124848 and CR1139514, 'A' main control room chiller failure to start, on June 12, 2019 and January 15, 2020.

(3) CR1139850, Unit 1 'A' reactor coolant pump seal differential pressures and leakoff flow changes, on January 21, 2020.

(4) CR1140081, NRC identified that the baseplate for charging service water pump 1-SW-P-10B has no grout covering gap between floor and pump, on January 24, 2020.

(5) CR1141394 and CR1141721, Unit 2 Letdown Over-pressurization Event on February 19, 2020.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:

(1) Unit 1 'A' main feedwater pump following shimming of the 1A1 motor feet while running on January 16, 2020.

(2) 0-OP-VS-006, Control Room and Relay Room Ventilation System, testing of the 'D' main control room chiller following maintenance package on January 17, 2020.

(3) Unit 1 'B' charging pump following preventative maintenance on the motor and several motor operated valves, on March 7, 2020.

(4) Unit 2 repair of letdown ion exchanger isolation valves under work orders (WOs)

===38204213804 and 38204213780, following pressure transient in CR1141394 and CR1141721 on March 23, 2020.

(5) Spent Fuel Building suction ventilation fan belt replacement and fan motor re-alignment under WO 38204211219 on March 25, 2020.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) 2-OPT-EG-001, #2 Emergency Diesel Generator Monthly Start Exercise, on January 13, 2020.

(2) 2-OPT-CS-002, Containment Spray System Test, on January 29, 2020.

(3) 2-PT-18.6I, Unit 2 Power Operated Relief Block Valve testing on February 18, 2020.

Inservice Testing (IP Section 03.01) ===

(1) 2-OPT-FW-003, Turbine Driven Auxiliary Feedwater Pump 2-FW-P-2, on January 24,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) ===

(1) Unit 1 (January 1 to December 31, 2019)

(2) Unit 2 (January 1 to December 31, 2019)

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)

(2 Samples)

(1) Unit 1 (January 1 to December 31, 2019)

(2) Unit 2 (January 1 to December 31, 2019)

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)

(1) Unit 1 (January 1 to December 31, 2019)

(2) Unit 2 (January 1 to December 31, 2019)

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in maintenance of permanently installed measuring and test equipment that might be indicative of a more significant safety issue.

Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) CR1126835, Fire suppression water system loop piping failure between 1-FP-86 and 1-FP-92

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

60855 - Operation of an ISFSI Operation of an ISFSI

(1) The inspectors evaluated the licensees activities related to long-term operation and monitoring of their independent spent fuel storage installation (ISFSI). This inspection included a detailed walkdown of the three ISFSI pads on March 24,

INSPECTION RESULTS

Observation: Observation on Status of Corrective Actions related to Fire 71152 Suppression Water System Piping Issues This observation is intended to provide a status of corrective actions related to the fire protection (FP) loop piping failures that occurred on July 13, 2019. This event was initially entered into the licensees corrective action program (CAP) as CR1126835, Fire Main Rupture between 1-FP-86 and 1-FP-92. In accordance with fleet procedure PI-AA-200, Corrective Action, CR1126835 was screened as Significance Level 3 (Condition Adverse to Quality) and as a potential repeat. To address CR1126835, the licensee created WO 38204200553 to replace the two ruptured pipe sections and developed a level of effort evaluation (LEE).

The LEE for CR1126835 was issued on August 6, 2019 as CA7644141. The inspectors reviewed CA7644141 and noted that it described the FP loop failure event in detail and identifies the following six corrective actions to be completed to address the issue:

1. Complete replacement of all fire protection piping between 1-FP-92 and 1-FP-86 in accordance with WO38204203071 (Status 22 - under development)

2. Verify Soil Analysis Report and Chemistry Water Sample Analysis confirms LEE

evaluation (CA7701873, Due Date: 12/19/2019)3. Develop plan for extent of condition and submit condition reports (CRs) for WO creation. Extent of condition will include destructive piping inspections, soil moisture samples/checks, and investigation of the source of water by piping failures (CA7701874, Due Date: 10/17/2019)4. Document extent of condition and initiate actions to restore fire protection Loop piping health (CA7701875, Due Date: 01/31/2020 and CA7724497, Due Date 12/31/2021)5. Modify Underground Piping and Tank Integrity program to address impact of soil corrosivity on cast iron piping (CA7702387, Due Date: 02/28/2020)6. Submit REA to develop Fire Protection Replacement Project through Plant Health Steering Committee (CA7711200, Due Date 04/23/2020)

At the time of the inspection, the soil analysis report (Item 2) and the extent of condition plan (Item 3) were complete. The license had also completed a near term extent of condition (Item 4, CA7701875), which included digging initial exploratory holes to check for the presence of groundwater.

All other corrective action items specified in the LEE were either being planned or in progress. At the time of the inspection, revisions to the Underground Piping and Tank Integrity Program (Item 5) were being tracked by the licensee under CA7702387, which had a due date of 02/28/2020. However, during a daily debrief with the licensee on 02/27/2020, the inspector was informed that the due date for program update was being extended to 04/23/2020. Regarding the extent of condition (Item 4), what remains to be done are the activities described in the licensees extent of condition plan (CA7701874), which calls for the excavation and destructive examination of piping at six locations along the fire protection loop. The inspector noted that 11 WOs have been created but all of them are currently listed as Status 22 (under development). Completion of the activities associated with the extent of condition plan is being tracked under CA7724497, which has a due date of 12/31/2021.

During a discussion on the actions proposed to determine the extent of condition, the inspectors questioned the licensee regarding the commitments made in the October 31st letter response to NRC comments on Dominions Annual Subsequent License Renewal Update Letter (ADAMS Accession Number ML19310E716), which include drilling a minimum of 25 holes around the fire protection loop prior to the subsequent period of extended operation to look for the presence of groundwater, and those proposed in CR1141740, dated 02/20/2020, which calls for 25 soil samples along the fire protection loop. The licensee responded that those actions should be considered as planned actions to be implemented if needed in the future. Finally, as part of the multi-year Fire Protection Replacement Project (Item 6), the licensee plans to replace all affected cast iron FP loop piping in four phases.

Phase 1 has been approved and will replace all FP loop piping between 1-FP-86 and 1-FP-46. The inspectors noted that Phase 1 includes replacing all piping between 1-FP-86 and 1-FP-92 and would therefore close corrective action item 1 upon completion. During an interview regarding the project, the licensee stated that the current plan is to replace the piping between 1-FP-92 and 1-FP-100 prior to the Spring 2020 Unit 2 refueling outage and to replace the remaining piping by the end of the calendar year. The licensee has identified the sections of the fire protection loop that will be covered by Phases 2, 3, and 4, but no timeframe has been determined for those phases. The licensee also indicated that the future need for piping replacement will be determined by examined piping and engineering input.

Replacement of the ruptured FP loop piping sections was completed on 09/17/2019. At that time, CR1131143 was generated to note that some fire protection loop piping between 1-FP-86 and 1-FP-92 would be returned to service with potential corrosion. Specifically, CR1131143 identifies a 35-foot section of cast iron fire protection piping that was not excavated, inspected, or replaced even though significant graphitic corrosion was identified in adjacent piping sections. Actions identified to close CR1131143 include developing a reasonable assurance of safety (RAS) to support the functional status of the piping between 1-FP-86 and 1-FP-92 as well as assigning a WO to replace the remaining piping in that section.

In addition to CR1126835, the inspectors noted that several other CRs related to this issue were written over time and as new information became available. Two CRs worth noting in this observation are CR1132464 and CR1133474. CR 1132464, generated on 10/03/2019, identified that a reasonable assurance of safety (RAS) could not be supported for the FP loop piping between 1-FP-86 and 1-FP-92, which resulted in the section being declared as nonfunctional. The inspectors noted that the section of the FP loop in CR1132464 is where the original failure occurred and, as described above, where piping adjacent to the ruptured sections was not excavated, inspected, or replaced. CR1132464 was closed to actions required by the Surry Technical Requirements Manual (TRM) and to WO 38204203071 and WO 38204203092, which are for piping excavation and replacement. With less than required equipment functional, Surry TRM Section 3.7.1.A requires that the equipment be restored to functional status or that the licensee provide an alternate means to accomplish the nonfunctional function within 7 days. At that time, the section of piping between 1-FP-86 and 1-FP-92 was already isolated and an alternate means to accomplish the function was in place. The inspectors also noted that the activities associated with WO 38204203071 and WO38204203092 are part of Phase 1 of the Fire Protection Replacement Project.

Subsequently, CR1133474, generated on 10/17/2019, identified that a reasonable assurance of safety on the FP loop piping could not be supported, which resulted in the entire FP loop being declared as nonfunctional. This CR was closed to actions required by the Surry TRM, RAS(CA7695715), and actions from CR1126835. With the no fire suppression water system functional, Surry TRM 3.7.1.D requires that a backup fire suppression water system be established within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Within that time, the licensee developed a RAS (CA7695715)supporting the reliability of a portion of the FP loop piping for use with the backup fire water pump to provide a backup water suppression system and put the system in place. The inspectors reviewed CA7695715 and noted that it also provided interim compensatory measures, which include establishing an hourly fire watch in the Unit 1 and Unit 2 turbine building as well as administrative controls to ensure that a backup fire water pump is available for firefighting activities when needed. The inspectors reviewed operating logs for 10/18/2019 and verified that the compensatory measures were put in place that day. When asked to clarify what actions associated with CR1126835 were applicable to closing this CR, the licensee responded that the specific actions are those related to the Fire Protection Replacement Project.

At the time of the inspection, the backup fire water suppression system and associated compensatory measures were still in place. During an interview, the inspectors questioned how long the backup system was expected to remain in place. The licensee responded that the backup system will remain in place until appropriate measures are taken to declare the fire protection supply piping functional. This may be accomplished through repair, replacement, or evaluation. The licensee also indicated that more information is needed before a more definite time frame for returning the fire water suppression system to a functional status can be determined.

Observation: Semiannual Trend Review of Permanently Installed Measuring and 71152 Test Equipment The inspectors performed a review of the licensee's use of permanently installed equipment used to demonstrate operability of safety-related equipment to determine if trends related to calibration and testing could indicate the existence of a more significant safety issue. This review was focused on measuring and test equipment that is used to demonstrate operability of safety-related equipment that did not fall under the licensee's procedure MA-AA-400, "Measuring and Test Equipment." The inspectors reviewed preventative maintenance records, procedures, and station logs.

The inspectors determined that the licensee, in general, has ensured that permanently installed measuring and test equipment associated with safety-related equipment is reliable. The inspectors found that preventative maintenance schedules were appropriate to maintain the equipment. The inspectors identified a process deficiency in two procedures associated with the calibration of pressure gauges in which calibration was permitted without adequate documentation of as-found deficiencies. Although these procedures are used to check and calibrate both nonsafety-related and safety-related components, inspectors did not identify any instances of safety-related equipment being unreliable as a result of the processes.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On April 20, 2020, the inspectors presented the integrated inspection results to Fred Mladen, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures 0-OP-ZZ-021 Severe Weather Preparation 24

71111.04 Corrective Action CR1125131

Documents

Miscellaneous Drone Footage Unit 1 'A' Reactor Coolant Pump Cubicle Drone Inspection 03/04/2020

Video

Procedures 0-OP-VS-006 Control Room and Relay Room Ventilation System 75

Work Orders 38204199518

71111.07A Calculations ME-0281 Component Cooling Heat Exchanger (CCHX) Operability 4

Curves

71111.11Q Corrective Action CR1142098 Unit 1 - Packing Leak identified following swap to Main

Documents Steam supply to Gland Steam

Resulting from

Inspection

71111.13 Miscellaneous PHOENIX Online 03/04/2020

Risk Modeling

PHOENIX Online 02/14/2020

Risk Modeling

PHOENIX Online 02/18/2020

Risk Modeling

Troubleshooting 01/08/2020

Sheet for

CR1138652 for

work on

component 1-FW-

P-1A1

71111.15 Calculations 6718-EP-S-1 Qualification of MER-3 Truss 0

Corrective Action CR1140081

Documents

71111.19 Procedures 0-MPM-0210-01 Control Room Chillers Performance Checks 30

0-OP-VS-006 Control Room and Relay Room Ventilation System 75

71111.22 Miscellaneous Vibration data for Printed

1. 2 EDG 1/13/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

monitoring points

Procedures 2-OPT-CS-002 Containment Spray System Test 19

2-OPT-EG-001 #2 EDG Monthly Start Exercise 80

71151 Miscellaneous Q4/2019

Performance

Indicators - Surry

and 2 -

Unplanned Power

Changes per

7000 Critical

Hours

Q4/2019

Performance

Indicators - Surry

and 2 -

Unplanned

Scrams per 7000

Critical Hours

Q4/2019

Performance

Indicators - Surry

and 2 -

Unplanned

Scrams with

Complications

71152 Corrective Action CAs (by number) 7644141, 7644142, 7695715, 7701873, 7701874, 7702387,

Documents CRs (by Number) 1120563, 1126168, 1126835, 1131143, 1131702, 1132464,

1133225, 1133474, 1141740

Drawings 11148-FB-3A Yard Water & Fire Protection Lines Rev. 27

Engineering ET-CME-07-0006 Surry Power Station Component Cooling Heat Exchanger 03/14/07

Evaluations 1A Performance Test

Miscellaneous ER-AA-BPM-10 Underground Piping and Tank Integrity Program Description Rev. 9

Procedures 0-OP-FP-006 Operation of Fire Protection Systems Rev. 19

CM-AA-FPA-100 Fire Protection/Appendix R (Fire Safe Shutdown) Program Rev. 13

Inspection Type Designation Description or Title Revision or

Procedure Date

ER-AA-BPM-101 Underground Piping and Tank Integrity Program Rev. 15

IMP-C-G-3 ITT Barton Differential Pressure Indication Calibration 18

IMP-C-MISC-147 Calibration/Test of Pressure Gauge 19

PI-AA-200 Corrective Action Rev. 35

Work Orders 38103832969

204197597

Work Orders (by WO38102939749, WO38102991510, WO38103030572,

Number) WO38103187330, WO38103520033, WO38103534697,

WO3820400553, WO38204203071, WO38204204002

13