IR 05000280/2022010
| ML22070A972 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 03/15/2022 |
| From: | James Baptist NRC/RGN-II/DRS/PSB1 |
| To: | Stoddard D Virginia Electric & Power Co (VEPCO) |
| Fanelli T | |
| References | |
| IR 2022010 | |
| Download: ML22070A972 (15) | |
Text
March 15, 2022
SUBJECT:
SURRY POWER STATION - NRC INSPECTION REPORT 05000280/2022010 AND 05000281/2022010
Dear Mr. Stoddard:
On February 4, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Surry Power Station and discussed the results of this inspection with James Holloway and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented 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 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. 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, James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety Docket Nos. 05000280 and 05000281 License Nos. DPR-32 and DPR-37 Enclosure:
NRC Inspection Report (IR) 05000280/2022010, 05000281/2022010 w/attachment: Appendix G Phase II Screening Signed by Baptist, James on 03/15/22
ML22070A972 x Non-Sensitive x Publicly Available x SUNSI Review Sensitive Non-Publicly Available
OFFICE RII:DRS RII:DRS RII:DRS RII:DRS NAME T. Fanelli C. Franklin C. Cauffman J. Baptist DATE 3/14/22 3/2/22 3/2/22 3/15/22
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers: 05000280 and 05000281
License Numbers: DPR-32 and DPR-37
Report Numbers: 05000280/2022010 and 05000281/2022010
Enterprise Identifier: I-2022-010-0019
Licensee: Virginia Electric and Power Company
Facility: Surry Power Station
Location: Surry, VA.
Inspection Dates: January 31, 2022 to February 04, 2022
Inspectors: C. Cauffman, Reactor Operations Engineer T. Fanelli, Senior Reactor Inspector C. Franklin, Reactor Inspector
Approved By: James B. Baptist, Chief Engineering Br 1 Division of Reactor Safety
Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a NRC 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
Failure to Verify DC Crosstie Design Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.17T Systems NCV 05000280,05000281/2022010-01 Open/Closed The inspectors identified a Green finding and an associated NCV of 10 CFR 50 Appendix B Criterion III, Design Control, for the licensee's failure to verify that DC train crosstie circuits were qualified to perform the required safety function and not fail under normal and design basis events specified by the postulated phenomena as outlined in IEEE 308-1974.
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.
REACTOR SAFETY
71111.17T - Evaluations of Changes, Tests, and Experiments Sample Selection (IP Section 02.01)
The inspectors reviewed the following evaluations, screenings, and/or applicability determinations for 10 CFR 50.59 from 1/31/2022 to 2/4/2022.
- (1) DCP-00-042, CW Canal Level Probe Missile Shield Replacement
- (2) DCP-02-029, FAC U1 Piping Replacement
- (3) DCP-04-051, RCP DP Transmitter Replacement
- (4) DCP-04-100, Replace Circuit Breakers and Verify Thermal Overload Settings for Control Room and Emergency Switchgear Room Air Handlers
- (5) DCP-05-025, Outside Recirculation Spray (ORS) Pump Test Loop Modifications
- (7) DCP-99-093, Replacement of Control Room Recorders with Paperless Recorders
- (8) SU-09-0036, Recirc Spray Heat Exchanger Service Water Monitoring System
- (9) SU-13-01053, EDG Data Acquisition System Quick Connect and Test Setup
- (10) SU-15-00006, Risk Release Reactor Coolant Pump 1-RC-P-1B Seal Face Change
- (13) SU-16-00115, Replacement/Modification of Two Pipe Supports on The Unit 2 Safety Injection System
- (16) SU-18-00116, Stem and Disc Arm Replacement For 1-SI-MOV-1863a
- (17) SU-18-00173, Reconfiguration of U2 Pressurizer Heaters, 10, 33, and 50
- (18) SU-19-00110, "A" RCP Floating Ring Seal Removal
- (19) SU-21-00135, 1-RC-HCV-1556A & C-Valve Spring Hanger Support Modification
- (20) SU-17-00123, Installation of Swagelok Fittings on 2-SS-PP-0.38-Pipe
- (21) SU-09-00046, Turbine Supervisory Instrumentation Replacement
- (22) SU-13-00008, 18" CC-229-121 And 18" CC-235-121 Repairs
- (23) SU-18-00160, VFD Swap for 1-LW-P-12/13
- (24) SU-19-00156, Modify 8"-CC-70-151 Hanger
- (25) SU-18-00159, Temp Mod, Temporary Modification CERPI System Shutdown Bank A No7 and Position Indication Detector Secondary Winding Resistance Signal
- (26) SU-17-00122, Reconfigure Unit 2 Pressurizer Heaters
- (27) SU-19-00134, 2020 Unit 2 FAC Modifications
INSPECTION RESULTS
Failure to Verify DC Crosstie Design Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.17T Systems NCV 05000280,05000281/2022010-01 Open/Closed The inspectors identified a Green finding and an associated NCV of 10 CFR 50 Appendix B Criterion III, Design Control, for the licensee's failure to verify that DC train crosstie circuits were qualified to perform the required safety function and not fail under normal and design basis events specified by the postulated phenomena as outlined in IEEE 308-1974.
Description:
Design Change No. SU-16-01064 replaced the DC crosstie molded case circuit breakers (MCCBs) in Unit 1 (1A-22 and 1B-21) and Unit 2 (2B-19 and 2A-22). The existing two-pole MCCBs, NB21200F, were replaced with three-pole MCCBs, HNB31200F. The manufacturer catalog, No. V12-T3-43, specified that, DC qualified MCCBs including the trip units are, two-pole breakers supplied in three-pole frames with current carrying parts omitted from center pole. Three-pole MCCBs and trip units were specified as AC only, [Alternating Current only]. The DC ratings were not applicable. The purchase order (PO) No. 4500398109 ordered 250 vac, 1200 amps, model HNB31200F with unit, magnetic trip, adjustable, model HNB312000TM. Not, DC qualified MCCBs. The PO neither specified the actual DC application requirements nor the required DC amperes of interrupting capacity (AIC). The HNB type MCCBs do not appear to have been formally qualified for the designs required AIC of more than 19,000A. The listed Underwriters Laboratory DC ratings for the two-pole HNB MCCBs was just 10,000A. Further, the design required one of the MCCBs to be in a reverse current flow condition while cross tied. The Eaton HNB Application Data,29-160, states, in part, that the NB and HNB breakers can be mounted in an inverted position but are not approved for reverse feed. This could further adversely affect the AIC rating of the MCCB. The inspectors determined that the MCCBs were not designed to clear a fault and withstand the available short circuit currents in the DC crosstie design.
One of the applicable licensing basis design standards, Institute of Electrical and Electronics Engineers (IEEE) 308-1974, section 4.1, General. stated, the Class 1E power systems shall be designed to assure that no design basis event will cause:
- (1) A loss of electric power to a number of engineered safety features, surveillance devices, or protection system devices sufficient to jeopardize the safety of the station, and
- (2) A loss of electric power to equipment that could result in a reactor power transient capable of causing significant damage to the fuel or to the reactor coolant system. And, Section 4.7, Equipment Qualification. stated each type of Class 1E power equipment shall be qualified by analysis, successful use under similar conditions, or by actual test to demonstrate its ability to perform its function under normal and design basis events. The design basis events specified included, in part, the following postulated phenomena: Fires; Fire-protection system operation; Accident generated flooding, sprays, or jets; Postulated loss of the preferred power supply combined with any of the above; Single equipment malfunction; Single act, event, component failure, or circuit fault that can cause multiple equipment malfunctions; and a Single equipment maintenance outage.
The inspectors determined that the HNB circuit breakers were not qualified to crosstie the two Class 1E DC trains while preventing a loss of electric power as specified in the design standard.
Corrective Actions: The licensee entered this issue into the corrective action program and placed danger/warning tags on the circuit breakers to prevent their use during outage operations.
Corrective Action References: CR1190494
Performance Assessment:
Performance Deficiency: The licensing basis design standard IEEE 308-1974, required Surry to ensure that each type of Class 1E power equipment shall be qualified to demonstrate its ability to perform its function under normal and design basis events as specified by the postulated phenomena. The failure to verify that DC train crosstie circuits were qualified to perform the required safety function and not fail under normal and design basis events specified by the postulated phenomena as outlined in IEEE 308-1974 was a performance deficiency.
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. Specifically, the performance deficiency could cause a loss of DC power to both trains causing a loss of required mitigating systems.
Significance: The inspectors assessed the significance of the finding using Appendix G, Shutdown Safety SDP. The inspectors initial Phase I screening required a phase II SDP to be performed. Attached is the completed SDP IMC 0609 Appendix G, attachment 2, Phase II screening completed by a Region II SRA, which characterizes this finding as GREEN.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Title 10 CFR 50, Appendix B, Criterion III, "Design Control," required, in part, "design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program."
Contrary to the above, the licensee failed to provide design control measures for verifying or checking the adequacy of the DC train crosstie circuit design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. Specifically, the licensee failed to verify that DC train crosstie circuits were qualified to perform the required safety function and not fail under normal and design basis events specified by the postulated phenomena as outlined in IEEE 308-1974.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On February 4, 2022, the inspectors presented the NRC inspection results to James Holloway and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.17T Calculations 01039.0810-E-Cable Sizing for 480V MCC Loads Related to DCP 90-15-3 0-00A
011
2846.36-NPB-Pipe Stress Analysis Problem 4093 of The Service Water 4
4093-X12 System
2846.39-NPN-Pipe stress evaluation of line 8"-WS-489-21X as the class of 1
4091-X12 the piping changed from 151 (Carbon steel) to 21X (Cu-Ni) per
14937.53-NPB-Pipe Stress Analysis: Service Water Piping In Valve Pit, Lines 0
007-XE 8"-WS-481, 482-21X Turbine / Service Building
EE-0499 DC Vital Bus Short Circuit Current 2
ME-0791 Sizing of ORS Pump Test Loop Piping 0
SU-CALC-PSP-Safety Injection - Show Cause Support/Restraint & Baseplate 5
2681
Drawings S-05025-2-Flow/Value Operating Numbers Diagram Recirculation Spray 2
2FM084B System Surry Power Station Unit 2 Virginia Power
Engineering DC-02-029 2003 FAC U1 Replacement / Surry/ Unit 1 11/07/2002
Changes DCP SU-18-Design Equivalent Change Package 1
00116
SU-06-045 SW Carbon Steel Piping Replacement with Copper-Nickel / 03/12/2007
Surry / Units 1 & 2
SU-09-00046 Turbine Supervisory Instrumentation Replacement I Surry I 01/21/2010
Unit I
SU-09-0036 Recirc Spray Heat Exchanger Service Water Monitoring 04/22/2010
System
SU-13-00008 18" CC-229-121 and 18" CC-235-121 Repairs 07/15/2013
SU-15-00006 Risk Release Reactor Coolant Pump 1-RC-P-1B Seal Face 07/15/2015
Change
SU-16-00115 Replacement/Modification of two pipe supports on the Unit 2 3
Safety Injection System
SU-17-00122 Reconfigure Unit 2 Pressurizer Heaters 0
SU-17-00123 Installation of Swagelok Fittings on 2-SS-PP-0.38-SS-PIPE-1
304-1CN9
Inspection Type Designation Description or Title Revision or
Procedure Date
SU-18-00159 Temporary Modification CERPI System Shutdown Bank A N07 0
Rod Position Indication Detector Secondary
Winding Resistance Signal
SU-19-00110 "A" RCP Floating Ring Seal Removal 1
SU-19-00156 Modify 8" CC-70-151 Hanger 0
SU-21-00135 1-RC-HCV-1556A & C-Valve Spring Hanger Support 0
Modification
SU-DCP-000-38-Replace Circuit Breakers and Verify Thermal Overload 03/01/2005
DCP-04-100 Settings for Control Room and
Emergency Switchgear Room Air Handlers/Surry/Unit 1 & 2
SU-DCP-000-38-ORS Pump Test Loop Modification/Surry/Unit2 04/27/2006
DCP-05-025
TM S2-17-150 Reconfiguration of Pressurizer Heaters 0
Engineering DC-SU-15-00006 50.59/72.48 Screen 7/15/15
Evaluations SU-09-00046 50.59/72.48 Screen 01/06/2010
SU-13-01053 EDG Data Acquisition System Quick Connect and Test Setup 14
SU-13-01053 50.59/72.48 Screen 0
SU-18-00116 Stem and Disc Arm Replacement for 1-SI-MOV-1863A 1
SU-19-00110 50.50/72.48 Screen 1
SU-19-00156 Design Equivalent Change Package
Miscellaneous Eaton 27.3-43 Molded-Case Circuit Breakers & Enclosures, Application Data, 04/01/2016
Table 27.3-13. Reverse-Feed ApplicationsEatons Circuit
Breakers
Eaton Application AB DE-ION Circuit Breakers, Standard Type NB, and MARK 12/01/1988
Data 29-160 75 700-1200 Amperes, 600 Volts Ac, 250 Volts Dc,CD 2 and
Poles Type NBY 240 Volts Ac, 700-1200 Amperes
Eaton Catalog Molded-Case Circuit Breakers, Volume 12, Aftermarket, 02/01/2019
V12-T3-1 Renewal Parts and Life Extension Solutions
EP-0026 Surry Unit 1, 2003 Refueling Outage Results of Secondary 0
Piping & Component Inspection Program
IEEE Standard IEEE Standard Criteria for Class 1E Power Systems for 03/14/1975
308-1974 Nuclear Power Generating Stations
Licensee Surry Power Station - 10CFR 50.59 Inspection Supplemental 02/09/2022
Response Information on DC Cross Tie Breakers
Inspection Type Designation Description or Title Revision or
Procedure Date
SU-PO-MAT-Incoming Insp. for GR for Purchase Order 0
4500398109-
00002-
000000264325
_42276061
Procedures 1K-A6, Batt Bus Tie Bkr Closed 3
1A/1B
2K-A6, Batt Bus Tie Bkr Closed 1
1A/1B
ER-AA-FAC-1001 Flow-Accelerated Corrosion (FAC) Susceptibility Analysis & 6
Modeling
ER-AA-FAC-1003 Flow-Accelerated Corrosion (FAC) Operational Experience 6
Reviews
ER-AA-FAC-102 Flow-Accelerated Corrosion (FAC) Inspection and Evaluation 1
Activities
ER-AA-FAC-104 Crossover/Crossunder Inspection & Evaluation Activities 1
STD-GN-0033 Secondary Piping and Component Inspection Program 9
SU-PROC-000-1-Removal from Service and Return to Service of Station Battery 16
MOP-EP-030 1A
SU-PROC-000-1-Removal From Service And Return To Service Of Station 16
MOP-EP-031 Battery 1B
VPAP-0807 Secondary Piping and Component Inspection Program 2
Work Orders 00524235 02 Replace Circuit Breakers and Verify Thermal Overload 02/20/2006
Settings Control Room and Emergency Switch Gear Air
Handlers
00524235 03 Replace Circuit Breakers and Verify Thermal Overload 02/20/2006
Settings Control Room and Emergency Switch Gear Air
Handlers
38077408903,
38077408902,
38072198008,
00774089-01,
00721980-01
IMC 0609 Appendix G Phase II Screening
Performance Deficiency: The licensing basis design standard IEEE 308-1974, required Surry to
ensure that each type of Class 1E power equipment shall be qualified to demonstrate its ability
to perform its function under normal and design basis electrical failure events. The failure to
ensure that the DC crosstie circuit breakers could meet the fault duty required by the design
basis electrical failure events was a performance deficiency.
Safety Consequence: DC breakers will not provide fault protection as designed and could result
in an unrecoverable Loss of All DC as the fault would not be cleared/isolated and both DC
buses would be damaged and not be recoverable. DC bus cross connection is only allowed in
Mode 5 by Tech Specs. Loss of DC power would remove all Control Power for Pumps and
Valves and remove all remote indications and alarms.
Note: Procedure 1-MOP-EP-030, Removing 1A Battery may only be performed in Refueling
shutdown (POS III), however 1-MOP-EP-031, Removing 1B Battery may be performed in Cold
shutdown or refueling shutdown (POS I, POS II, or POS III). DC buses being cross connected
is limited to 7 days due to a TS LCO for the non-outage unit
Bottom Line Screen to Green in phase II, may re-exit with a Green NCV. Since the report was
not issued no SDP clocks were started for the TBD AV.
ANALYSIS
1. This is a Conditional Finding so IELs from IMC 0609 Appendix G Attachment 2 Table 5,
Initiating Even Likelihoods (IELs) for Condition Findings - PWRs. Assume exposure
period of 7 days (column 2)
LOOP 2
LORHR 2
LOI 3
LOLC 2 (2 for all exposure periods)
2. Use the DC bus Faulting basic event from the SPAR Model DCP-BDC-LP-1A (B)
(FAILURE OF 125V DC BUS 1A (B)) = 5.108 E-6 events/year
3. IEL for DC bus failure during exposure period: (DCP-BDC-LP-1A OR DCP-BDC-LP-1B)
x exposure time = (5.108 E-6 + 5.108 E-6) x (7/365) = 1.9E-7
4. Conditional so Add IEL + IE for DC Bus Failure to get Conditional IEL
LOOP 2 + 7 = 9
LORHR 2 + 7 = 9
LOI 3 + 7 = 10
LOLC 2 +7 =9
5. IMC 0609 Appendix G Attachment 2 worksheets 1-7 are applicable for shutdown
initiating event LOLC, LOOP, and LOI in a 3 Loop Westinghouse PWR. Worksheets 8
and 9 are used for a LORHR for a 4 loop Westinghouse plant. (Conservatively used in
this case despite it being a 3 loop Westinghouse)
6. Worksheet 1 LOLC POS I
a. LOLC-SG-RHR-R-RWSYMU - 9
b. LOLC-SG-Feed & Bleed - 9
7. Worksheet 2 LOLC POS II
a. LOI-RHR-R-RWSTMU - 10
b. LOI-Feed - 10
8. Worksheet 3 LOOP POS I
a. LOOP-EAC-SGSBO-RLOOP3 -9 + 1 = 10
9. Worksheet 4 LOOP POS II
a. LOOP-EAC-RLOOP18 - 9 + 1 =10
b. LOOP-EAC-Gravity-RLOOP4 - 9 + 1 = 10
10.Worksheet 5 LOI POS I
a. LOI-SG-RHR-R-RWSTMU - 10
b. LOI-SG-BLEED -10
c. LOI-LEAKSTOP-RWSTMU -10
d. LOI--FEED-SG - 10
e. LOI-FEED-LEAKSTOP -10
11.Worksheet 6 LOI POS II
a. LOI-RHR-R-RWSTMU - 10
b. LOI-LEAKSTOP-RWSTMU-10
c. LOI-FEED -10
2.Worksheet 7 LOI POS III
a. LOI-RHR-R -10
b. LOI-RHR-LEAKSTOP-10
c. LOI-FEED-10
13.Worksheet 8 LORHR POS I
a. LORHR - RHR-S - SG - RHR-R-RWSTMU -9
b. LORHR - RHR-S - SG - FEED&BLEED - 9
14.Worksheet 9 LORHR -POS II
a. LORHR - RHR-S - RHR-R - RWSTMU - 9
b. LORHR - RHR-S - FEED - 9
Totals
1-MOP-EP-031 (B Battery disconnected) (POS I, II, and III )
x 10
x 9
Counting Rule:
10s: 16/3 (round down)=5
9s: (6+5)/3 (round down)=3
8s: (3+2)/3 (round down) = 1
7s: (0+1)/3 (round down =0
6s: 0 therefore GREEN
1-MOP-EP-030 (A Battery disconnected) (POS III only)
X 10
Counting Rule:
10s 3/3 (round down) = 1
9s (1+0)/3 (round down) =0
8s: 0
7s: 0
6s: 0 therefore Green
3