IR 05000280/2020011

Biennial Problem Identification and Resolution Inspection Report 05000280/2020011 and 05000281/2020011

ML20269A203
Person / Time
Site:	Surry
Issue date:	09/24/2020
From:	Stewart Bailey NRC/RGN-II/DRP/RPB4
To:	Stoddard D Virginia Electric & Power Co (VEPCO)
References
IR 2020011
Download: ML20269A203 (14)

Text

September 24, 2020

SUBJECT:

SURRY POWER STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000280/2020011 AND 05000281/2020011

Dear Mr. Stoddard:

On August 14, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Surry Power Station and discussed the results of this inspection with Mr. Doug Lawrence and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.

Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

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 and 05000281 License Nos. DPR-32 and DPR-37

Inspection Report

Docket Numbers: 05000280 and 05000281 License Numbers: DPR-32 and DPR-37 Report Numbers: 05000280/2020011 and 05000281/2020011 Enterprise Identifier: I-2020-011-0032 Licensee: Virginia Electric and Power Company Facility: Surry Power Station Location: Surry, VA Inspection Dates: July 13, 2020 to August 14, 2020 Inspectors: A. Patz, Senior Resident Inspector P. Niebaum, Senior Project Engineer V. Petrella, Reactor Inspector C. Taylor, Sr. Construction 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 a biennial problem identification and resolution 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.

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 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.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

(1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.

• Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted an in-depth review of the safety injection system, safety-related heating, ventilating, and air conditioning systems, and portions of the fire protection system.

• Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits, and self-assessments.

• Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B 1. Corrective Action Program Effectiveness Based on the samples reviewed, the team determined that the licensees corrective action program (CAP) complied with regulatory requirements and self-imposed standards. The licensees implementation of the CAP adequately supported nuclear safety.

Problem Identification: The inspectors determined that the licensee was 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 a review of the requirements for initiating Condition Reports (CRs) as described in licensee procedure PI-AA-200, Corrective Action, and managements expectation that employees were encouraged to initiate CRs for any reason. Additionally, 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 selected systems, the inspectors determined that deficiencies were being identified and placed in the CAP.

Prioritization and Evaluation of Issues: Based on the review of CRs sampled by the inspection team during the inspection period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the CR significance determination guidance in procedure PI-AA-200. The inspectors determined that, in general, adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that plant personnel had conducted root cause and other types of cause analyses in compliance with the licensees CAP procedures. The cause determinations were considered appropriate and addressed the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used to evaluate CRs depending on the type and complexity of the issue consistent with the applicable cause evaluation procedures.

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. The inspectors reviewed performance indicators, CRs, and effectiveness reviews, as applicable, to verify that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to preclude repetition (CAPRs)were sufficient to ensure corrective actions were properly implemented and were effective.

2. Operating Experience, Self-Assessments, and Audits

The inspectors examined the licensee's program for obtaining and using industry operating experience. This included review of procedure PI-AA-100-1007, "Operating Experience Program," selected corrective program action requests, and the licensees operating experience (OE) database to assess the effectiveness of how external and internal OE data was handled at the plant. Additionally, the inspectors selected OE documents such as NRC generic communications, licensee event reports, vendor notifications, and plant internal OE items which had been issued since October 2018 to verify whether the licensee had appropriately evaluated each notification for applicability to Surry, and whether issues identified through these reviews were entered into the CAP.

The team determined that stations processes for the use of industry and NRC operating experience information and for the performance of audits and self-assessments were effective and complied with regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The team concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented to address lessons learned as needed. The inspectors determined that the licensee was effective at performing self-assessments and audits to identify issues at a low level, properly evaluated those issues, and resolved them commensurate with their safety significance.

3. Safety-Conscious Work Environment

Based on a sample size of approximately 20 people interviewed from a cross-section of plant employees, the team found no evidence of challenges to a safety-conscious work environment. Employees interviewed appeared willing to raise nuclear safety concerns through at least one of the several means available.

Minor Performance Deficiency 71152B Minor Performance Deficiency: The NRC identified a minor performance deficiency when the station failed to comply with licensee procedure PI-AA-200, Corrective Action. Specifically, a crack was found in the 1-SI-147 valve disc during a maintenance activity, work order (WO)38103775308, and documented in an engineering technical evaluation, ETE-SU-2020-010, in April 2018. Although the valve disc was replaced, the crack was not documented in the associated work order or in a condition report (CR). PI-AA-200, section 3.1.4 directed all personnel to submit a CR for any issue or concern that does not meet specific requirements of procedures, policies, management expectations or accepted industry standards. It further directs licensee staff to see Attachments 1 and 2 of PI-AA-200 for guidance and examples of issues requiring condition report submittal. Attachment 1, Examples of Conditions that Require a [condition adverse to quality] CAQ CR, item 26, stated:

An event, condition, or situation, which on its own, is a condition potentially adverse to quality or meets the criteria for submitting a condition report, even if the item will be addressed by a separate process.

Screening: The inspectors determined that this issue was minor in accordance with NRCs inspection manual chapter (IMC) 0612, Issue Screening. Specifically, the performance deficiency could not be reasonably viewed as a precursor to a significant event, would not have the potential to lead to a more significant safety concern, and was not associated with one of the cornerstone attributes and did not adversely affect a cornerstone objective. The licensee placed this into their corrective action program (CAP) as CR 1152637.

Minor Violation 71152B Minor Violation: The NRC identified a minor violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action. Specifically, the licensee failed to correct a CAQ associated with nonfunctional emergency alarm beacons located in the diesel generator rooms and Units 1 and 2 charging pump cubicles. The alarm beacons are part of the Gaitronics System which is described in the Emergency Plan and Equipment Important to Emergency Response (EITHER) list.

The NRC reviewed (CR 1125292 and the associated work order (WO) 38103181113 and identified that this issue had been originally identified in December 2010 (CR406694) as a CAQ. Subsequent CRs over the years identified the same issue. The licensee determined that emergency alarm beacons needed to function as designed. Replacement parts were not available, and the WO dated June 2012 stated system circuits cards should be sent out for refurbishment. However, the WO priority level was eventually changed from a priority level 4 to 6, which allowed the WO corrective action to be cancelled per procedure, WM-AA-100, Work Management.

Screening: The inspectors determined that this issue was minor in accordance with NRCs inspection manual chapter (IMC) 0612, Issue Screening, IMC 0612, App. B, Additional Issue Screening Guidance and IMC 0612, App. E, Examples of Minor Issues. Specifically, the performance deficiency could not be reasonably viewed as a precursor to a significant event; if left uncorrected, would not have the potential to lead to a more significant safety concern and did not adversely affect the emergency preparedness cornerstone objective.

Specifically, compensatory measures were in place to test the areas on a periodic frequency for audibility.

Enforcement:

This failure to comply with 10 CFR Part 50, Appendix B, Criterion XVI constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee entered this issue into their CAP as CR 11525596.

Minor Violation 71152B Minor Violation: The NRC identified a minor violation of License Condition 3.I, Fire Protection, for the failure to implement and maintain in effect the provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR). Specifically, Section 9.10.2.2.5 of the UFSAR states that heat collector plates are installed per National Fire Protection Association (NFPA) requirements over sprinkler heads that are under grating walkways in the turbine building. Contrary to this requirement, heat collector plates had been removed from 20 total sprinklers in the Unit 1 and Unit 2 turbine buildings.

On October 24, 2018, the licensee identified in CR 1108429 that 17 total heat collector plates on fire suppression sprinklers in the upper elevations of the turbine building had been removed. In CR 1119165, the licensee determined that these plates should be replaced, and WO 38204196454 was written to restore these sprinklers. On August 3, 2020, the NRC asked the licensee to determine if any sprinklers in the turbine building were under grating without these protective plates for all turbine building elevations. The licensee found three additional sprinklers without the protective plates under grating in the Unit 1 and Unit 2 turbine building. The licensee determined that the absence of these heat collector plates sprinklers would not affect any safe shutdown equipment.

Screening: This violation was considered minor as a credible scenario in which the missing plates could significantly impact safe shutdown equipment was not identified.

Enforcement:

This failure to comply with License Condition 3.I constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee entered this issue into their CAP as CR 1152904 and CR 1152908.

Minor Violation 71152B Minor Violation: The NRC identified a minor violation of Technical Specification (TS) 6.4, Unit Operating Procedures and Programs, for the failure to follow the facility fire program in procedure CM-AA-FPA-101, Control of Combustible and Flammable Materials.

On July 16, 2020, the NRC performed an inspection of the Unit 2 Safeguards area and identified two rolled up rubber hoses between the ladders that lead to the Unit 2 Train "A" low head safety injection pump and Unit 2 Train "A" outside recirculating spray pump. Upon identification, the licensee removed the hoses.

TS 6.4.E, requires that the facility fire protection program and implementing procedures which have been established for the station be implemented and maintained. The facility fire protection program is partially implemented by procedure CM-AA-FPA-101. Attachment 10 to this procedure states that a transient fire loading report is required for the Unit 2 safeguards and main steam valve house, Fire Zone 20. Contrary to this requirement, the licensee did not complete a transient fire loading report before storing combustible material in the area.

Screening: This violation was considered minor as the transient combustible loading in this fire zone was maintained less than the maximum allowed combustible loading. Additionally, a credible scenario in which the hoses could affect safety related equipment was not identified.

Enforcement:

This failure to comply with TS 6.4.E constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee entered this issue into their CAP as CR 1152534.

Observation: Extent of Cause for Plant Transient 71152B The inspectors reviewed the corrective actions for a trip of an instrument air compressor and resulting plant transient on Unit 1 that occurred on October 16, 2018. In this event, an instrument air compressor tripped while operating as the only supply for its respective instrument air header. A dedicated operator attempted to open a supply valve but did not have enough time before an air-operated heater drain valve closed on low pressure and caused a plant transient. After the issue was entered into the Corrective Action Program, a Level of Effort Evaluation (LEE) was completed in CA7410246. The licensee accurately identified the direct cause of the compressor trip and eliminated the immediate vulnerability by changing the surveillance procedure and adding a preventive maintenance task.

The NRC documented non-cited violation (NCV)05000280/2018004-01 against 10 CFR 50.65(a)(4) for a failure to assess and manage the risk associated with the instrument air compressor surveillance testing. Additionally, the NRC noted that the dedicated operator could not have performed their respective risk mitigating action in time. After this violation was issued, the LEE remained unchanged and an Organizational and Programmatic Analysis Checklist was performed to address the violation. This checklist also had a narrow scope in that it only addressed the direct cause of the air compressor trip and heater drain valve closure. Because of this narrow scope, the licensee did not evaluate the station for more general vulnerabilities associated with the NRC-identified violation. Specifically, vulnerabilities in dedicated operator actions and improperly classified risk of procedures could still exist.

EXIT MEETINGS AND DEBRIEFS

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

• On August 14, 2020, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Doug Lawrence and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Corrective Action Condition Report 406694, 442940, 461997, 477997, 534294, 567966, 580220,

Documents (CR) 582048, 1053195, 1058648, 1080295, 1083519, 1098928,

1098949, 1098949, 1098950, 1104910, 1105505, 1107393,

1107786, 1108080, 1108087, 1108156, 1108429, 1108446,

1108675, 1108722, 1108771, 1108906, 1108906 ,1109104,

1109335, 1109534, 1110097, 1110552, 1110620, 1110714,

1110716, 1110771, 1111044, 1111173, 1111327, 1111342,

1111542, 1111648, 1111713, 1112168, 1112878, 1113049,

1113228, 1113654, 1113848, 1114072, 1114097, 1114417,

1114655, 1114993, 1115900, 1116832, 1116926, 1117532,

1117575, 1117584, 1119165, 1119187, 1119256, 1119548,

20264, 1120364, 1120496, 1121959, 1122772, 1123053,

23110, 1123661, 1123785, 1124009, 1124133, 1124184,

24404, 1124530, 1125025, 1125181, 1125292, 1125525,

25594, 1125953, 1125967, 1127189, 1127190, 1127282,

27472, 1127572, 1127945, 1127946, 1127948, 1128023,

28716, 1128749, 1129055, 1129105, 1129461, 1129648,

1131426, 1132556, 1132777, 1133775, 1134305, 1134760,

1134760, 1134937, 1135557, 1136383, 1136651, 1136909,

1136925, 1136925, 1137952, 1138147, 1138293, 1138374,

1138515, 1138756, 1138895, 1139093, 1139098, 1139197,

1140204, 1140749, 1140927, 1140967, 1141726, 1142081,

1143050, 1143051, 1143157, 1143251, 1143467, 1143713,

1143825, 1144065, 1144121, 1144207, 1144290, 1144296,

1145751, 1146038, 1146332, 1147101, 1147332, 1148738,

1149127, 1149555, 1149555, 1149697, 1151304, 1152138,

1152138

Corrective 3034685, 7287917, 7287919, 7287920, 7287923, 7287927,

Actions 7289716, 7289716, 7289717, 7380572, 7390748, 7390757,

7407546, 7407559, 7410210, 7410246, 7415958, 7415960,

20250, 7434181, 7436295, 7436298, 7443080, 7471478,

Inspection Type Designation Description or Title Revision or

Procedure Date

7477743, 7477744, 7477745, 7478631, 7480807, 7480811,

7480812, 7480840, 7481404, 7513387, 7513388, 7513402,

7513403, 7513404, 7517964, 7629584, 7630174, 7653778,

7653786, 7653788, 7653790, 7666185, 7671181, 7703426,

7716637, 7785414, 7811051, 7861016, 7861409, 8060993

PIR 1138249 Part 21-Reported Failure in Analog High Range Radiation

Monitor (RP-2C)

PIR 1143365 Part 21 - Notification of Defect Pursuant to 10 CFR 21 for

17FA999-1200-107 Oil Pump

PIR 1143709 Part 21 - Westinghouse-Log No. 2019-33-01 Closure of

Westinghouse

PIR 1149300 Part 21- Failure of Size 1 and 2 Freedom Series Auxiliary

Contacts (Paragon Energy)

Corrective Action CM-AA-FPA-101 Control of Combustible and Flammable Materials Rev. 11

Documents CR 1152534 Transient combustible stored in Unit 2 safeguards valve pit 07/29/2020

Resulting from without transient fire loading report

Inspection CR 1152596 Work order 38103181113 was cancelled without the Rev. 0

condition in the CR being corrected

CR 1152904 U1 turbine building sprinklers are missing heat collector plate 08/05/2020

CR 1152908 U2 turbine building sprinkler is missing heat collector plate 08/05/2020

Engineering 80-003A Plant Communications Systems Alarms 01/17/1980

Changes

Engineering ETE-SU-2011- Evaluation of permanently stored combustible material at 02/26/2020

Evaluations 0109 Surry

ETE-SU-2019- Shimming Mechanical Seals for Low Head Safety Injection Rev. 0

0063 Pumps

ETE-SU-2020- Mechanical Agitation of 1-SI-147 Rev. 0

0010

Miscellaneous Surry Check Valve Condition Monitoring Program for Valve Rev. 3

Group 1-009b

Ventilation System Top Issues List 07/09/2020

Surry Response: IE Bulletin 79-18 11/29/1979

Unit 1 Operations Aggregate Impact 06/03/2020

Unit 2 Operations Aggregate Impact 06/03/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

Safety Injection (SI) System Health Report 03/01/2020

SI System Health Report 10/01/2018

SI System Health Report 03/01/2019

SI System Health Report 10/01/2019

SI System Health Report 03/01/2020

MR (a)(1) Action Plan - Charging Pump Cubicle Backflow 04/22/2020

Preventers

(a)(1) Action Plan Unit 2 Failed Fuel 04/22/2019

(a)(1) Action Plan 1-BS-FLW-10 (MER 5 Flood Dike) 04/22/2019

(a)(1) Action Plan CH Pump Cubicle BFPs 04/15/2020

(a)(1) Action Plan 2-RP-BKR-52-RTB 04/22/2019

(a)(1) Action Plan Unit 2 AFW System Inoperable 01/28/2020

(a)(1) Action Plan 1-IA-C-3 04/22/2019

(a)(1) Action Plan 1-IA-C-1 08/21/2019

1-OPT-SI-025 Closure testing of Accumulator Discharge Check Valves 11/28/2019

NRCODP-52-S Safety Injection System 08/11/2014

SDBD-SPS-SI Safety Injection System Design Basis Document Rev. 26

Procedures IST Program Basis Interval 5 Rev. 1

0-LOG-AUX- Operations Log Procedure Rev. 33

001R

0-MPM-1900-02 Flood Protection Backflow Preventer Testing and Installation Rev. 19

0-NPT-HATH- Ongoing Assessment of Critical Digital Assets for Hathaway Rev. 0

73.54.7

1-GOP-1.1 Unit Startup, RCS Heatup From Ambient to 195F Rev. 60

1-GOP-2.6 Unit Cooldown, Less than 250F to Ambient Rev. 46

1-GOP-2.8 Unit Cooldown, HSD to CSD for Refueling Rev. 39

2-GOP-1.1 Unit Startup, RCS Heatup From Ambient to 195F Rev. 56

2-GOP-1.7 Unit Startup, RCS Heatup From Ambient to HSD Rev. 36

2A-G3 Annunciator Response Procedure - LHSI PP 1A Seal Hd Rev. 9

Tank Lo Lvl

EC-AA-110 Identifying and Addressing Nuclear Safety and Quality Rev. 1

Concerns

EP-AA-303 Equipment Important to Emergency Response Rev. 21

Inspection Type Designation Description or Title Revision or

Procedure Date

ER-AA-102 Preventative Maintenance Program Rev. 12

ER-AA-MRL-100 Implementing Maintenance Rule Rev 12

ER-AA-PRS-1011 Just in Time Preventive Maintenance Review Process Rev. 8

ER-AA-SYS-1001 System Health Report Rev. 12

ER-AP-BAC-101 Boric Acid Corrosion Control Program (BACCP) Inspections Rev. 13

LI-AA-301 Implementation of 10 CFR 21, Reporting of Defects and Rev. 2

Noncompliance

OP-AA-102 Operability Determination Rev 15

OP-AA-1700 Operations Aggregate Impacts Rev. 8

PI-AA-100-1007 Operating Experience Program Rev. 18

PI-AA-200 Corrective Action Rev. 35

PI-AA-300 Cause Evaluation Rev. 17

PI-AA-300-3007 Level of Effort Evaluation Rev. 0

WM-AA-100 Work Management Rev. 34

Self-Assessments PIR 1113251 Maintenance, Engineering, RP/Chem, and Training

Departments Self-Assessment

PIR 1118906 Operations Aggregate Impact Self Assessment

Work Orders Work Order (WO) 38103181113, 38103181113, 38103475615, 38103475615,

38103626817, 38103702274, 38103725900, 38103775308,

38103840089, 38103850154, 38103861857, 38204180689,

204182349, 38204182350, 38204182351, 38204182409,

204183955, 38204188071, 38204191204, 38204192445,

204196072, 38204196454, 38204198193, 38204200284,

204200894, 38204202372, 38204204645, 38204209931,

204215315, 38204219814, 38204221962

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