IR 05000280/2020004
| ML21033B025 | |
| Person / Time | |
|---|---|
| Site: | Surry, 07200055, 05000200 |
| Issue date: | 02/02/2021 |
| From: | Stewart Bailey Division Reactor Projects II |
| To: | Stoddard D Virginia Electric & Power Co (VEPCO) |
| References | |
| IR 2020003, IR 2020004 | |
| Download: ML21033B025 (21) | |
Text
February 2, 2021
SUBJECT:
SURRY POWER STATION - INTEGRATED INSPECTION REPORT 05000280/2020004 AND 05000281/2020004; 07200055/2020003
Dear Mr. Stoddard:
On December 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Surry Power Station. On January 20, 2021, the NRC inspectors discussed the results of this inspection with Mr. Doug Lawrence, Surry Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Surry Power Station.
If you disagree with a cross-cutting aspect assignment 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Surry Power Station. 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 and 05000281 License Nos. DPR-32 and DPR-37
Enclosure:
As stated
Inspection Report
Docket Numbers: 05000280 and 05000281 License Numbers: DPR-32 and DPR-37 Report Numbers: 05000280/2020004 and 05000281/2020004; 07200055/2020003 Enterprise Identifier: I-2020-004-0056; I-2020-003-0079 Licensee: Virginia Electric and Power Company Facility: Surry Power Station Location: Surry, VA Inspection Dates: October 01, 2020 to December 31, 2020 Inspectors: L. McKown, Senior Resident Inspector B. Towne, Resident Inspector D. Dumbacher, Senior Operations Engineer 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
Surry Unit 2 Failure to Identify Auxiliary Feedwater Header Drain Line Seismic Interference Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.2] - 71111.15 Systems NCV 05000281/2020004-01 Evaluation Open/Closed The inspectors identified a Green finding and non-cited violation (NCV) of 10 CFR 50 Appendix B, Criterion XVI, Corrective Action, associated with Dominion Energys failure to identify a condition adverse to quality based upon the discovery of an interference between the Surry Unit 2 A Auxiliary Feedwater (AFW) header 2-FW-139 drain cap and A AFW header seismic support on October 6, 2020.
Surry Unit 2 Alarm Response to Loss of Normal Containment Cooling Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.14] - 71111.15 NCV 05000281/2020004-02 Conservative Open/Closed Bias The inspectors identified a Green finding and associated non-cited violation (NCV) of Surry Power Station Technical Specification (TS) 6.4 Unit Operating Procedures and Programs, subsection A.3 associated with alarm response when the licensee failed to provide an adequately detailed procedure to respond to alarm conditions due to the loss of normal containment cooling. Specifically, on August 4, 2020, challenges with procedure implementation resulted in the failure to assess degradation of containment conditions.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000281/2020-001-00 Cancellation of LER 2020- 71153 Closed 001-00 for Surry Power Station Unit 2 re Loss of Containment Cooling Affecting Containment Partial Pressure Indication.
LER 05000281/2020-001-00 LER 2020-001-00 for Surry 71153 Closed Power Station Unit 2, Loss of Containment Cooling Affecting Partial Pressure Indication
PLANT STATUS
Unit 1 operated at or near rated thermal power for the entire inspection period.
Unit 2 began the period at rated thermal power. On December 4, 2020, the unit was down powered to approximately 75 percent in support of planned maintenance on the 'A' main condenser circulating waterbox. The unit was returned to rated thermal power on December 4, 2020 and remained at or near rated thermal power for the remainder of the 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 Disease 2019 (COVID19), resident inspectors were directed to begin teleworking and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed on-site portions of IPs. 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 some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
External Flooding Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding in October 2020.
- Emergency Service Water Pump House
- Safeguards Building
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1 Safeguards Exhaust Ventilation subsystem of Units 1 and 2 Auxiliary Ventilation System on October 1, 2020.
- (2) Unit 1 Auxiliary Feedwater 'A' and 'B' Supply Headers on November 3, 2020.
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Emergency Service Water system on November 16, 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) Units 1 and 2 Mechanical Equipment Room #3 on October 29, 2020.
- (2) Unit 2 Upper Cable Vault Area on November 9, 2020.
- (3) Unit 1 Emergency Switchgear room on December 22, 2020.
- (4) Unit 2 Emergency Switchgear room on December 22, 2020.
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
The licensee completed the annual requalification operating examinations required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2), Requalification Requirements, of the NRCs Operators Licenses. During the week of November 9, 2020, the inspector performed an in-office review of the overall pass/fail results of the individual operating examinations, the crew simulator operating examinations, and the biennial written examinations in accordance with Inspection Procedure (IP) 71111.11, Licensed Operator Requalification Program. These results were compared to the thresholds established in Section 3.02, Requalification Examination Results, of IP 71111.
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered on October 20, 2020.
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 turbine inlet valve stroke testing including a down power to 97 percent and return to rated thermal power on November 10, 2020.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)
- (1) The inspectors observed and evaluated a licensed operator requalification training scenario involving shutdown operations with loss of core cooling and loss of coolant accidents on October 21, 2020.
- (2) The inspectors observed and evaluated a licensed operator requalification training scenario involving an airline strike hazard as well as steam generator rupture with faults across all trains of main steam and loss of all auxiliary feedwater on October 27, 2020.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Unit 1 Safety Injection Accumulator Relief Valves following multiple spurious lifts on November 18, 2020.
- (2) Unit 2 Turbine Driven Auxiliary Feedwater Pump Steam Admission Valves based upon observed leakby on December 4, 2020.
- (3) Unit 1 Main Control Room and Emergency Switchgear Room Chillers following a series of failures and preventive maintenance windows on December 7, 2020.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (2 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 Intake Canal Level Logic Testing concurrent with Motor Driven Fire Pump out of service for preventive maintenance on October 6, 2020.
- (2) Concurrent planned removal of Spent Fuel Pool Cooling Heat Sink with Independent Spent Fuel Storage Installation Campaign, 34.5kV Intake transformer switching, and containment entry on October 21, 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) CR1152857, loss of unit 2 normal containment cooling on October 1, 2020.
- (2) CR1157426 and CR1158885, Unit 2 'A' Auxiliary Feedwater Supply header drain line seismic interference on October 7, 2020.
- (3) CR1158321, 'C' Charging Pump Discharge motor operated valve alternative first time lineup during preventative maintenance on October 14, 2020.
- (4) CR11607271 and CR1160470, failed carbon dioxide fire protection seals at Units 1 and 2 upper cable tunnel vault exterior doors 1-BS-DR-61 and 2-BS-FR-64 on November 17, 2020.
- (5) CR1162317, Step change in unit 2 reactor cooling sump inleakage on December 14, 2020.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Unit 2, 'B' charging pump return to service following preventive maintenance, work order (WO) 38103865530 and WO38103604035, on October 1, 2020.
- (2) Unit 1, 'A' motor driven auxiliary feedwater pump following delayed identification of pump packing leakage, WO38204224648, on October 2, 2020.
- (3) Unit 1, failure of 1-CH-MOV-1286A, 'A' Charging Pump Normal High Head Safety Injection Supply Isolation Valve in mid-position, WO38204225336, on October 20, 2020.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Unit 1, 0-IPT-CNL-LGC-8.8, Intake Canal Level Logic Testing, on October 6, 2020.
- (2) Unit 1, 1-OPT-SI-005, Unit 1 Low Head Safety Injection Surveillance Testing, on
===October 15, 2020.
FLEX Testing (IP Section 03.02) (1 Sample)===
- (1) 0-MPM-1960-01, Semi-Annual or Annual Test of BDB FLEX Equipment, as performed under WOs 38204199842, 38204199968, and 38204199892, inspected on December 1, 2020.
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) The inspectors evaluated a licensee emergency planning drill in the simulator and technical support center, on October 27, 2020. The drill involved an airline strike hazard as well as steam generator rupture with faults across all trains of main steam and loss of all auxiliary feedwater.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===
- (1) Unit 1 (April 1, 2019 through September 30, 2020)
- (2) Unit 2 (April 1, 2019 through September 30, 2020)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)
- (1) Unit 1 (April 1, 2019 through September 30, 2020)
- (2) Unit 2 (April 1, 2019 through September 30, 2020)
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
- (1) Unit 1 (April 1, 2019 through September 30, 2020)
- (2) Unit 2 (April 1, 2019 through September 30, 2020)
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 sustainability of corrective actions associated with externally identified conditions adverse to quality that might be indicative of a more significant safety issue.
71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000281/2020-001-00, Loss of Containment Cooling Affecting Containment Partial Pressure Indication, (ADAMS Accession No. ML21027A119). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71111.15. This LER was submitted and subsequently retracted by licensee correspondence titled Cancellation of Licensee Event Report, dated November 6, 2020 (ADAMS Accession No. ML21027A120).
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants Operation of an Independent Spent Fuel Storage Installation at Operating Plants
- (1) The inspectors evaluated the licensees independent spent fuel storage installation cask loadings on November 2, 2020 through November 13, 2020. Specifically, the inspectors observed the following activities:
- Fuel selection and fuel loading,
- Heavy load movement of transfer cask,
- Drying and backfill evolutions,
- Non-destructive evaluations, and
- Radiological field surveys.
INSPECTION RESULTS
Surry Unit 2 Failure to Identify Auxiliary Feedwater Header Drain Line Seismic Interference Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.2] - 71111.15 Systems NCV 05000281/2020004-01 Evaluation Open/Closed The inspectors identified a Green finding and non-cited violation (NCV) of 10 CFR 50 Appendix B, Criterion XVI, Corrective Action, associated with Dominion Energys failure to identify a condition adverse to quality based upon the discovery of an interference between the Surry Unit 2 A Auxiliary Feedwater (AFW) header 2-FW-139 drain cap and A AFW header seismic support on October 6, 2020.
Description:
On October 6, 2020, during a plant status walkdown of the Surry Unit 2 AFW system, the NRC inspectors identified a modified seismic support in direct contact with an upstream threaded drain cap on the 2-FW-139, A AFW header drain, a 0.75-inch drain line on the 6-inch A AFW header. The seismic support is designed to protect the AFW header in the vertical direction only during a design basis seismic event. The piping is unrestrained in the horizontal plane such that in a seismic event the drain cap would move with the AFW header while the modified support would move with the building, the main steam valve house.
The interference at the point of contact between the drain cap and modified support could create elevated stresses at the drain line which could challenge the A AFW header.
The station captured this condition adverse to quality in condition report (CR)1157426. Surry analysis of seismic calculations found that by taking into account thermal expansion as well as potential movement of the header and the building respectively, there was a total of 0.736 inch of potential displacement at the point of contact during an event. However, licensee engineers determined that the location could only accept up to 0.066 inch of potential displacement without exceeding design stress limits. Therefore, the station removed the drain line cap mitigating the interference condition.
The inspectors observed that while the station did mitigate the immediate safety concern, they failed to assess the impact of the as found condition on the capability of AFW to support its safety functions during a design basis events given the potential seismic displacement exceeding acceptance criteria. The station captured this condition adverse to quality in CR1158885 which identified that a plastic analysis in accordance with ASME III Appendix F would be required to determine the impact on the AFW past functionality. This finite element analysis established 0.58 inch as the plastic deformation failure criteria for the piping and connections. As this value was less than the initially assessed potential design basis displacement for the point of interference, Dominion Engineering performed further reviews using revised assumptions and analyses. This action established a revised potential total displacement of the location of 0.562 inch with a safety margin of 0.018 inch.
Corrective Actions: Upon identification, Dominion Energy removed the A AFW header drain cap downstream of 2-FW-139 mitigating the interference while generating additional corrective actions to reroute the configuration and evaluate past functionality.
Corrective Action References: CR1157426, CR1158885
Performance Assessment:
Performance Deficiency: The inspectors found that Dominion Energys failure to identify the interference between the drain cap downstream of 2-FW-139, A AFW header drain, and an AFW header seismic support was a performance deficiency reasonably within the licensees ability to foresee and prevent.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Reasonable assurance of the as found capability of A AFW header was lost based upon the licensee staffs initial analysis exceeding design basis stress limits requiring a plastic deformation evaluation. The inspectors used IMC 0612, Appendix E, Examples of Minor Issues, dated January 1, 2020, to inform answers to the more than minor screening questions finding this condition consistent with more than minor examples 3.a, e, f, g, and i.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. This finding was determined to be of very low safety significance (Green), when all screening questions were answered no based upon information provided in Dominion Energys plastic deformation evaluation.
Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. This finding in accordance with IMC 0310, Aspects within the Cross-Cutting Areas, dated February 25, 2019, has a cross-cutting aspect in the Problem Identification cross-cutting area associated with Evaluation, in that Dominion Energy staff failed to investigate the past functionality of AFW based upon safety significance of the as found condition.
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, Criterion XVI, Corrective Action, states in part, Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
Contrary to the above, until discovery on October 6, 2020, measures established by Dominion Energy failed to assure that conditions adverse to quality, such as the deficiencies and nonconformances resulting in the interference between the Surry Unit 2 A AFW header 2-FW-139 drain cap and A AFW header seismic support, were promptly identified and corrected.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Surry Unit 2 Alarm Response to Loss of Normal Containment Cooling Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.14] - 71111.15 NCV 05000281/2020004-02 Conservative Open/Closed Bias The inspectors identified a Green finding and associated non-cited violation (NCV) of Surry Power Station Technical Specification (TS) 6.4, Unit Operating Procedures and Programs, subsection A.3 associated with alarm response when the licensee failed to provide an adequately detailed procedure to respond to alarm conditions due to the loss of normal containment cooling. Specifically, on August 4, 2020, challenges with procedure implementation resulted in the failure to assess degradation of containment conditions.
Description:
On August 4, 2020 at 1835, Surry Unit 2 lost normal containment cooling due to a loss of containment chill water, the non-safety related system which is the heat sink for normal containment cooling during power operation. TS 3.8.D.1 required containment conditions including containment air partial pressure and containment air temperature within an operating range provided in TS Figure 3.8-1 while above 350F and 450 psig, RCS temperature and pressure.
Upon alarm, operators entered annunciator response procedure (ARP) 2B-A6 CTMT PART PRESSURE - 0.1 PSI CH1, and 2B-B6, CTMT PART PRESSURE - 0.1 PSI CH2, which contain equivalent steps for channels 1 and 2 respectively. Operators reached step 6 and declared both channels of containment air partial pressure indicators inoperable as these instruments require a functional containment chill water system to remain reliable. These indicators are the only direct measure of containment air partial pressure available.
The inspectors spoke with the operations shift manager at 2000 to understand plant status and compliance with TS 3.8.D.1, specifically if the operators had determined if the unit was outside of the operating range in TS Fig 3.8-1. The shift manager informed that as of 1955 the shift had evaluated that unit 2 was outside of the range, later specifying out of the range low, and would be entering the TS 3.8.D.1.a. 1-hour shutdown action statement. At 2056 containment chill water was restored. With normal containment cooling in service, the associated annunciators cleared, containment air partial pressure indicators returned to functionality, and containment conditions began to return to normal. However, inspectors learned that the unit never entered the TS 3.8.D.1.a action statement.
The inspectors discovered that after their 2000 call, the shift manager conferred with station management who observed that ARP 2B-A6 and 2B-B6 contain applicable cautions and notes. These state in part, CTMT partial pressure indication less than minimum pressure allowed by Technical Specification Figure 3.8-1 due to chiller trip or known chiller or Chilled Water evolution does NOT constitute violation of Tech Spec 3.8. Additionally, Performance of this calculation [Calculation of CTMT Air Partial Pressure] immediately after loss of CTMT cooling is not required, however, it must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of the last satisfactory surveillance.
The inspectors observed, however, that technical specifications do not support this position.
Moreover, reviews of design and license basis documentation revealed no additional evaluations or regulatory guidance to establish these cautions and notes within the ARPs.
The station determined that their position was based upon external operating experience at a similar station with a different operating range who had used surveillance frequencies as a basis for assessment of a similar condition. Surry chose 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> based upon operator rounds as their technical specifications lacked a discrete surveillance frequency.
Though lacking a technical justification for delaying containment parameter assessment, ARP 2B-A6 & 2B-B6 each provide two means to accurately evaluate containment conditions and TS 3.8.D compliance in the event of the loss of containment air partial pressure indication. The first, attachment 2, Calculation of CTMT Air Partial Pressure, steps 1-6, is an analytical methodology that can be performed using information readily available from plant process computer indications and standard engineering tables in a reasonably short period of time as performed by the shift during the event. The second, steps 7-13, is a direct determination requiring a containment entry, measurement, and sampling of the atmosphere which the licensee identified as requiring reasonably significant time and resources.
When the inspectors performed the containment air partial pressure assessment in accordance with the ARPs, attachment 2, steps 1-6, they discovered that containment air partial pressure was outside of the operating range for the duration of the event. Moreover, these results were low out of band just as discovered by the operators during their 1955 evaluation. The inspectors then expanded the evaluation window beyond the August 4 event, finding that under most operating conditions the analytic methodology for determining containment air partial pressure provided in the ARP would indicate that the unit was in noncompliance with TS 3.8.D.
In consultation with agency subject matter experts, the inspectors determined that while the provided analytical methodology is one of several valid means to assess containment air partial pressure within a reasonably short period of time, it is conservative based upon normal plant operating conditions and initial assumptions. However, when normal containment air partial indication is inoperable and operators rely only on the analytical method provided in ARP 2B-A6 & 2B-B6, the unit will likely appear to be in noncompliance with TS 3.8.D under normal operating conditions.
Corrective Actions: Dominion Energy generated Surry Power Station LER 2020-001, dated October 1, 2020, in response to the inspectors findings pursuant to requirements 10 CFR 50.73(a)(2)(v)(D) and 10 CFR 50.73(a)(2)(vii) due to their untimeliness of alarm response and apparent TS 3.8.D non-compliance. In a letter dated November 6, 2020, Dominion Energy cancelled LER 2020-001 based upon completion of an engineering evaluation indicating TS 3.8.D compliance using a different calculation methodology. Additionally, the station has implemented temporary guidance and established corrective actions to close gaps in ARP 2B-A6 and 2B-B6 as well as associated procedures.
Corrective Action References: CR1154065, CR1152857
Performance Assessment:
Performance Deficiency: The inspectors found that Dominion Energys failure to provide adequate detailed instructions in the alarm response procedures ARP 2B-A6 and 2B-B6 was a performance deficiency reasonably within the licensees ability to foresee and prevent.
Specifically, this resulted in a delayed assessment of an apparent TS 3.8.D, Containment Internal Pressure, noncompliance associated with a loss of normal containment cooling event on August 4, 2020.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Reasonable assurance of containment protection was lost based upon the apparent noncompliance with TS 3.8.D due to the analytical methodology for containment air partial pressure provided within ARP 2B-A6 and 2B-B6. Consistent with more than minor examples 3.a, e, f, g, and i of IMC 0612, Appendix E, Examples of Minor Issues, dated January 1, 2020, Dominion Energy performed an engineering evaluation using a different calculation methodology and revised assumptions to obtain favorable results to restore reasonable assurance.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. This finding was determined to be of very low safety significance (Green), when all screening questions were answered no based upon information provided in Dominion Energys evaluation using a method alternative to that provided in ARP 2B-A6 and 2B-B6 at the time of the event.
Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. This finding in accordance with IMC 0310, Aspects within the Cross-Cutting Areas, dated February 25, 2019, has a cross-cutting aspect in the Human Performance cross-cutting area associated with Conservative Bias. Dominion Energy operators did not take timely action to address degraded containment internal pressure parameters commensurate with the safety significance of the TS 3.8.D.1.a 1-hour shutdown action statement and the unexpected results of the analytical methodology due to the language in the notes, cautions, and directions provided in the ARP 2B-A6 and 2B-B6.
Enforcement:
Violation: Technical Specification 6.4.A. states in part, Detailed written procedures with appropriate check-off lists and instructions shall be provided for the following conditions:
Actions to be taken for specific and foreseen malfunctions of systems or components including alarms, primary system leaks and abnormal reactivity changes.
Contrary to the above, until discovery on August 4, 2020, Dominion Energy did not provide detailed written procedures with appropriate check-off lists and instructions for the actions to be taken for the loss of normal containment cooling including control room annunciators (alarms) 2B-A6, CTMT PART PRESSURE - 0.1 PSI CH1 and 2B-B6, CTMT PART PRESSURE - 0.1 PSI CH2 which resulted in the failure to assess degradation of containment conditions and apparent non-compliance with TS 3.8.D, Containment Internal Pressure.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Trend Review of Repeat NRC Identified Conditions Adverse to 71152 Quality The inspectors performed a review of potential adverse trends in sustainability of corrective actions associated with NRC-identified conditions adverse to quality that might be indicative of a more significant safety issue. The inspectors sampled a population of maintenance records, documented inspections, condition reports, and log entries during the period of December 6, 2018, through December 6, 2020.
Based upon the sample population reviewed, the inspectors found that while some conditions recurred or were similar to those previously captured within the corrective action program none were indicative of an apparent unidentified adverse trend or weakness associated with a significant condition adverse to quality. The inspectors did not identify any findings as a result of this inspection.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 20, 2021, the inspectors presented the integrated inspection results to Mr. Doug Lawrence, Surry Site Vice President and other members of the licensee staff.
THIRD PARTY REVIEWS The inspectors reviewed World Association of Nuclear Operators reports that were issued during the inspection year.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
60855.1 Miscellaneous Loading for Spent October
Fuel Pool 2020
60855.1 Miscellaneous S1-OP-20-03 Fuel Handling Report
60855.1 Miscellaneous S1-OP-20-04 Fuel Handling Report
60855.1 Procedures 0-OP-FH-072 NUHOMS 32 PTH Dry Shielded Canister Loading and 032
Handling
71111.04 Corrective Action CR1156755
Documents
Resulting from
Inspection
71111.04 Corrective Action CR1157426
Documents
Resulting from
Inspection
71111.04 Corrective Action CR1158885
Documents
Resulting from
Inspection
71111.04 Drawings 11448-FB-006D, Flow/Valve Operating Numbers Diagram Auxiliary 14
SH-001 Ventilation System
71111.04 Drawings 11548-FM-068A Feedwater System 62
SH-001
71111.05 Corrective Action CR1160470
Documents
Resulting from
Inspection
71111.05 Fire Plans 0-FS-FP-115 Mechanical Equipment Room #3 9 feet - 6 inch 004
71111.05 Fire Plans 2-FS-FP-103 Unit 2 Upper Cable Vault 35 feet - 6 inch 003
71111.05 Fire Plans 2-FS-FP-107 Unit 2 Emergency Switchgear Room 9 feet - 6 inch 006
71111.05 Fire Plans 2-FS-FP-107 Unit 1 Emergency Switchgear Room 9 feet - 6 inch 003
71111.11Q Miscellaneous S1C30 Reactivity Management Plan - Unit 1 Turbine Inlet Valve 11/10/2020
RXMANP03.3 Freedom Testing
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.11Q Procedures 1-OSP-TM-001 Turbine Inlet Valve Freedom Test 43
71111.11Q Procedures VPAP-1102 Periodic Testing 12
71111.12 Corrective Action CR1149697,
Documents CA8075254
71111.12 Corrective Action CR1151748,
Documents CR1152395,
CR1151760
71111.12 Corrective Action CR1159981,
Documents CR1156484,
CR1156319,
CR1155606,
CR1154718,
CR1154648,
CR1153488,
CR1153486,
CR1153297,
CR1153134,
CR1153061,
CR1152644,
CR1152572,
CR1152423,
CR1152308,
CR1152138,
CR1151942,
CR1151747
71111.12 Work Orders 38204220908,
204220546,
204221168
71111.13 Corrective Action CR1157512
Documents
Resulting from
Inspection
71111.13 Corrective Action CR1157553
Documents
Inspection Type Designation Description or Title Revision or
Procedure Date
Resulting from
Inspection
71111.13 Corrective Action CR1157553 and
Documents CR1157512
Resulting from
Inspection
71111.13 Miscellaneous PHOENIX Scheduler's Evaluation for Surry Power Station, 10/21/2020
Units 1 and 2
71111.13 Miscellaneous PHOENIX Scheduler's Evaluation for Surry Power Station, 10/06/2020
Units 1 and 2
71111.15 Corrective Action CR013693
Documents
71111.15 Corrective Action CR1152857
Documents
Resulting from
Inspection
71111.15 Corrective Action CR1154065
Documents
Resulting from
Inspection
71111.15 Corrective Action CR1157426
Documents
Resulting from
Inspection
71111.15 Corrective Action CR1158885
Documents
Resulting from
Inspection
71111.15 Engineering 12846.22-NSB- Surry Unit 2 Main Steam Valve House Seismic Analysis 0
Evaluations 001-JBH
71111.15 Engineering 14937.41-NPB- Surry Unit 2 Auxiliary Feedwater Seismic Analysis, R1, Add.
Evaluations 007-XE 00C
71111.15 Engineering ETE-SU-2020- Containment Air Partial Pressure Calculation 0
Evaluations 0057
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.15 Miscellaneous SPS Unit 2 Control Room Logs August 4,
20
71111.15 Procedures ARP 2B-A6 CTMT PART PRESS -0.1 PSI CH 1 (WITH 2 9
ATTACHMENTS)
71111.15 Procedures ARP 2B-B6 CTMT PART PRESS -0.1 PSI CH 2 (WITH 2 9
ATTACHMENTS)
71114.06 Miscellaneous SOCT20 FS Emergency Preparedness Drill Plan 10/27/2020
71151 Miscellaneous Unit 1 Control Room Narrative Logs, April 1, 2019 through
September 30, 2020.
71151 Miscellaneous Unit 2 Control Room Narrative Logs, April 1, 2019 through
September 30, 2020.
71151 Miscellaneous 4Q/2020 4Q/2020 Performance Indicators - Surry 1 and 2 - Reactor 9/1/2020 -
Performance Coolant System Activity 12/31/2020
Indicators - Surry
and 2 - Reactor
Coolant System
Activity
71151 Miscellaneous NEI 99-02 Regulatory Assessment Performance Indicator Guideline 7
71151 Miscellaneous UFSAR Chapter UFSAR Chapter 9.6, Sampling System Revision
9.6, Sampling 52.01
System 10/29/2020
71151 Procedures 1-OP-SS-001A Sample System Alignment Revision 9,
1/3/2019
71152 Corrective Action CR1116045, Review of NRC identified condition reports
Documents CR1116455,
CR1118135,
CR1118180,
CR1119305,
CR1120797,
CR1120821,
CR1120834,
CR1121520,
CR1121772,
CR1121793,
Inspection Type Designation Description or Title Revision or
Procedure Date
CR1121808,
CR1121809,
CR1121814,
CR1123227,
CR1123332,
CR1124183,
CR1124184,
CR1125825,
CR1126121,
CR1126123,
CR1127217,
CR1127585,
CR1127852,
CR1128490,
CR1129011,
CR1131000,
CR1131151,
CR1131344
18