IR 05000280/2021011

Triennial Fire Protection Team Inspection Report 05000280/2021011 and 05000281/2021011

ML21306A114
Person / Time
Site:	Surry
Issue date:	11/01/2021
From:	Scott Shaeffer Division of Reactor Safety II
To:	Lawrence D Dominion Energy Virginia
References
IR 2021011
Download: ML21306A114 (16)

Text

November 1, 2021

SUBJECT:

SURRY POWER STATION - TRIENNIAL FIRE PROTECTION TEAM INSPECTION REPORT 05000280/2021011 AND 05000281/2021011

Dear Mr. Lawrence:

On October 8, 2021, the U.S. Nuclear Regulatory Commission (NRC ) completed an inspection at Surry Power Station. On October 7, 2021, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The resul ts of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is document ed in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation 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 Reg ulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies t o 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 (CCA) 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 Administ rator, 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/

Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety

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: 05000280/2021011 and 05000281/2021011

Licensee: Dominion Energy Virginia

Facility: Surry Power Station

Location: Surry, VA

Inspection Dates: September 20, 2021 to October 08, 2021

Inspectors: L. Jones, Senior Reactor Inspector W. Monk, Senior Reactor Inspector (Team Lead)

J. Montgomery, Senior Reactor Inspector M. Singletary, Reactor Inspector

Approved By: Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety

Enclosure SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitori ng the licensees performance by conducting a triennial fire protection team insp ection (FPTI) 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 commerci al nuclear power reactors.

Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Inadequate Corrective Actions for Incorrect OMA Step in FCA Ope rating Procedure Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.14] - 71111.21N.

Systems NCV 05000280/2021011-01 Conservative 05 Open Bias The NRC identified a Green Non-Cited Violation (NCV) of Surry U nit 1 OLC 3.I, Fire Protection, for the licensees failure to implement adequate co rrective actions for an inadequate Fire Contingency Action (FCA) operating procedure.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of th e inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise note d. Currently approved IPs with their attached revision histories are located on the public web site 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 inspe ction activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Wa ter Reactor Inspection Program - Operations Phase. The inspectors reviewed selected p rocedures and records, observed activities, and interviewed personnel to assess licens ee performance and compliance with Commission rules and regulations, license conditions, site procedures, and industry standards. Starting on March 20, 2020, in response to the Nati onal Emergency declared by the President of the United States on the public health risks of th e coronavirus (COVID-19),

inspectors were directed to begin teleworking. In addition, re gional baseline inspections were evaluated to determine if all or a portion of the objectives an d requirements stated in the IP could be performed remotely. If the inspections could be perfo rmed 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 a nd requirements for completion of the IP.

REACTOR SAFETY

71111.21N.05 - Fire Protection Team Inspection (FPTI)

Structures, Systems, and Components (SSCs) Credited for Fire Pr evention, Detection, Suppression, or Post-Fire Safe Shutdown (SSD) Review (IP Sectio n 03.01) (4 Samples)

The inspectors verified that components and/or systems will fun ction as required to support the credited functions stated for each sample. Additional inspe ction considerations are located in the fire hazards analysis (FHA) or safe shutdown ana lysis (SSA).

a. Review deficiencies or open fire protection impairments for the selected system, including any temporary modifications, operator workarounds, or compensat ory measures.

b. Verify that operator actions can be accomplished as assumed in the licensees FHA, or as assumed in the licensees fire probabilistic risk assessment (F PRA) analysis and SSA.

c. Review repetitive or similar maintenance work requests which could be an indicator of a design deficiency and could affect the ability of the component s to perform their functions, when needed.

d. Ensure that post maintenance and/or surveillance activities are performed as scheduled.

e. Perform a walkdown inspection to identify equipment alignmen t discrepancies. Inspect for deficient conditions such as corrosion, missing fasteners, crac ks, and degraded insulation.

f. Ensure the selected SSCs that are subject to aging managemen t review (AMR) pursuant to 10 CFR Part 54 are being managed for aging (e.g., loss of ma terial, cracking, reduction of heat transfer) in accordance with appropriate aging management programs. Verify that the licensees aging management program activities (such as, Fuel O il Analysis or Selective Leaching Aging Management Program) associated with FP equipment are being implemented.

g. If a review of operating experience issues will be completed for the selected inspection sample, verify that the licensee adequately reviewed and dispos itioned the operating experience in accordance with their processes.

(1) SSC #1 (Fire Prevention): Transient Combustible Controls an d Hot Work Programs

(2) SSC #2 (Detection/Suppression): Low Pressure CO2 Fire Suppr ession System (3) SSC #3 (SSD): U1 & U2 Emergency Diesel Generator (EDG) Syst em and Emergency Power System Bus (4) SSC #4 (SSD): Auxiliary Feedwater (AFW) System

Fire Protection Program Administrative Controls (IP Section 03. 02) (2 Samples)

The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis. If applicable, ens ure that the licensees FPP contains adequate procedures to implement the selected administ rative control. Verify that the selected administrative control meets the requirements of a ll committed industry standards.

(1) Fire Protection Admin Program #1: Fire Protective Equipment Surveillance Program (2) Fire Protection Admin Program #2: Fire Brigade Drills and T raining Program

Fire Protection Program Changes/Modifications (IP Section 03.03 ) (2 Samples)

The inspectors verified the following:

a. Changes to the approved FPP do not constitute an adverse eff ect on the ability to safely shutdown.

b. The adequacy of the design modification, if applicable.

c. Assumptions and performance capability stated in the SSA ha ve not been degraded through changes or modifications.

d. The FPP documents, such as the Updated Final Safety Analysis Report, fire protection report, FHA, and SSA were updated consistent with the FPP or de sign change.

e. Post-fire SSD operating procedures, such as abnormal operati ng procedures, affected by the modification were updated.

(1) FPP Changes Mod / DCP #1: DCP DU-18-00112 - Charging SW Fir e Protection Pipe Replacement (2) FPP Changes Mod / DCP #2: DCP SU-16-00108 & 109 - U1/U2 AFW MOV Hot-Short Resolution

INSPECTION RESULTS

Inadequate Corrective Actions for Incorrect Operator Manual Act ion Step in FCA Operating Procedure Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.14] - 71111.21N.0 Systems NCV 05000280/2021011-01 Conservative 5 Open Bias The NRC identified a Green Non-Cited Violation (NCV) of Surry U nit 1 OLC 3.I, Fire Protection, for the licensees failure to implement adequate co rrective actions for an inadequate Fire Contingency Action (FCA) operating procedure.

Description:

On May 13, 2021, the licensee discovered that step 20 d) of fir e SSD procedure 1-FCA-3.00, Limiting Cable Vault and Cable Tunnel Fire, referenced the inco rrect breaker for de-

energizing the U1 480V J motor control centers (MCCs). The st ep called for operators to open breaker 1-EP-BKR-14J1-3. The correct breaker to de-energiz e the 480V J MCCs is breaker 1-EP-BKR-14J1-4. Breaker 1-EP-BKR-14J1-3 is for an alte rnate feeder to a filter exhaust fan, and this breaker is normally maintained racked out during normal plant operations. The procedure directed operators to take steps to d e-energize the U1 480V 'J'

MCC because it removes power from various motor operated valves (MOVs) in order to assure the MOVs remain in their required SSD position to assure adequate charging flow to the Reactor Coolant System and Auxiliary Feedwater flow to the steam generators. Upon discovery, the licensee entered the issue into the corrective a ction program (CAP) as Condition Report (CR) 1172768 and the issue was characterized a s a condition adverse to quality. The initial actions taken were to notify supervision, and to submit the issue to the sites Feedback Incorporation Process (FIP). The FIP process wa s not a part of the sites CAP program, and actions taken within the FIP process are not o fficially tracked or monitored as a part of the CAP. Additionally, the CR did not contain any other corrective actions nor note any other compensatory measures taken.

On October 4, 2021, during an inspection walkdown, inspectors d iscovered that step 20 d) of procedure 1-FCA-3.00 was still incorrect. Inside the FIP proces s, the proposed change was qualitatively given a priority of six months for the stations procedures group to respond, and no justification for this timeframe was required to be given. A dditionally, in June 2021, plant personnel erroneously interpreted an all procedures freeze requ est from the stations training group to mean that the FCA (among other site Emergency Operatin g Procedures and Abnormal Operating Procedures) should not be updated until at l east September 2021.

Corrective Actions:

• Operations department to update 1-FCA-3.00.

• Operations department to review Lessons Learned for timeliness of FIP submittal process and implementation.

• Extent of condition review of the site's other FCAs.

Corrective Action References:

• CR 1181961, NRC issuing Green NCV for Timeliness of Implementation, 10/05/2021

Performance Assessment:

Performance Deficiency: The licensee's failure to correct an operator manual action (OMA)

step error in 1-FCA-3.00, Limiting Cable Vault & Cable Tunnel F ire as soon as practical was a performance deficiency.

Screening: The inspectors determined the performance deficiency was mor e than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone and adversely affected the corne rstone objective to ensure the availability, reliability, and capability of systems that r espond to initiating events to prevent undesirable consequences. Specifically, the failure to correct the OMA step error as soon as practical allowed an error that reduced the reliability of an F CA procedure to exist for over five months.

Significance: The inspectors assessed the significance of the finding usin g Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspec tors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. Using IMC 0609, Appendix F, Attachment 1, the inspectors determined the issue was

of very low safety significance (Green) because the finding did not increase the likelihood of a fire, delay detection of a fire, or result in a more significan t fire than previously analyzed such that the credited safe shutdown strategy could be adversely imp acted (Question 1.4.1-A).

Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-pr actices that emphasize prudent choices over those that are simply allow able. A proposed action is determined to be safe in order to proceed, rather than unsafe i n order to stop. H.14 (Conservative Bias) - Individuals use decision making-practices that emphasize prudent choices over those that are simply allowable. Individuals did not use decision-making practices that emphasize prudent choices over those that are si mply allowable because when the FCA error was initially discovered no immediate corrective actions were taken nor any compensatory measures were put in place. Additionally, prompt a nd corrective action to correct the Fire SSD procedure was not taken.

Enforcement:

Violation: Surry Unit 1 Operating License Condition 3.I requires, in pa rt, that the licensee shall implement and maintain in effect the provisions of the ap proved fire protection program, as described in the Updated Final Safety Analysis Report (FSAR). Section 9.10.1 of the FSAR states, in part, that the Surry Power Station satisfies th e regulatory criteria set forth in Appendix A to Branch Technical Position APCSB 9.5-1 and that co mpliance with this criteria is contained within, among other documents, the Dominion fleet Fire Protection Program document. Section 3.11 of the Fire Protection Program document CM-AA-FPA-100 states, in part, that all aspects of the fire protection program shall be implemented in accordance with Topical Report DOM-QA-1, Dominion Nuclear Facility Quality Assu rance Program Description (QAPD). Section 16.1 of DOM-QA-1 states, in part, t hat the Company has established and implements corrective action programs, procedur es, and processes to assure that conditions adverse to quality at Company nuclear fa cilities are promptly identified and corrected. Section 16.4 states that the Company commits to meeting the standards for corrective action of NQA-1-1994, Part I, Basic Requirement 16. Basic Requirement 16 of Part 1 to NQA-1-1994 states that conditions adverse to quality shall be identified promptly and corrected as soon as practical.

Contrary to the above, from May 13, 2021 to October 4, 2021, th e licensee failed to assure that a condition adverse to quality was corrected as soon as pr actical.

Enforcement Action: This violation is being treated as a non-cited violation (NC V),

consistent with Section 2.3.2 of the NRCs Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained nor documented in this report.

• On October 7, 2021, the inspectors presented the triennial App endix R fire protection team inspection (FPTI) results to Mr. Doug Lawrence, Site Vice President and other members of the licensee staff.

THIRD PARTY REVIEWS

Inspectors reviewed one Institute of Nuclear Power Operations ( INPO) report, in reference to an inspection sample which was issued before the inspection period. No other third-party reviews were conducted.

7