IR 05000280/2022011

Biennial Problem Identification and Resolution Inspection Report 05000280/2022011 and 05000281/2022011

ML22187A009
Person / Time
Site:	Surry
Issue date:	07/06/2022
From:	Matthew Fannon Division Reactor Projects II
To:	Stoddard D Virginia Electric & Power Co (VEPCO)
References
IR 2022011
Download: ML22187A009 (17)

Text

July 6, 2022

SUBJECT:

SURRY POWER STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000280/2022011 AND 05000281/2022011

Dear Mr. Stoddard:

On May 26, 2022, the U.S. Nuclear Regulatory Commission (NRC) c ompleted a problem identification and resolution inspection at your Surry Power St ation. On May 26, 2022, the NRC inspectors discussed the results of this inspection with David Wilson and other members of your staff. The results of this inspection are documented in the en closed report.

The NRC inspection team reviewed the stations corrective actio n 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 co mplying with NRC regulations and licensee standards for corrective action programs. Based o n 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 indu stry and NRC operating experience information and the effectiveness of the stations a udits and self-assessments.

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

Finally, the team reviewed the st ations 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-conscio us work environment. Your employees appeared willing to raise nuclear safety concerns thr ough at least one of the several means available.

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 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/

Matthew S. Fannon, 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: 05000280/2022011 and 05000281/2022011

Licensee: Virginia Electric and Power Company

Facility: Surry Power Station

Location: Surry, VA

Inspection Dates: May 09, 2022 to May 26, 2022

Inspectors: J. Seat, Senior Project Engineer K. Carrington, Senior Resident Inspector D. Merzke, Senior Reactor Operations Engineer M. Schwieg, Senior Reactor Inspector B. Towne, Resident Inspector

Approved By: Matthew S. Fannon, Chief Reactor Projects Branch 4 Division of Reactor Projects

Enclosure SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitori ng 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

Transient Combustible Stored in a Restricted Area Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.5] - 71152B Systems NCV 05000280/2022011-01 Operating Open/Closed Experience An NRC identified finding of very-low safety significance (Gree n) and an associated Non-Cited Violation (NCV) of License Condition 3.I, Fire Protection, asso ciated with the licensee's failure to implement and maintain in effect, the provisions of the appr oved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR), which resulted in storage of a transient combustible within a restricted or combustion free zone.

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 procedures and records, observed activities, and interviewed personnel to assess licens ee 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 03.04) (1 Sample)

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

• Problem Identification and Resolution Effectiveness: The inspe ctors assessed the effectiveness of the licensees CAP in identifying, priorit izing, evaluating, and correcting problems. The inspectors conducted an in-depth corrective action program review of the auxiliary feedwater, service water, and fire protection systems. The inspectors also conducted a review of chilled water system deficiencies identified within the past five years or mo re.

• Operating Experience: The inspectors assessed the effectivenes s of the licensees processes for use of operating experience.

• Self-Assessments and Audits: The inspectors assessed the effec tiveness of the licensees identification and correction of problems identi fied through audits and self-assessments.

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

INSPECTION RESULTS

Assessment 71152B 1. Corrective Action Program Effectiveness

Based on the samples reviewed, the team determined that the lic ensee's performance in each of the following areas adequately supported nuclear safety, and in general, met the requirements in licensee procedure PI-AA-200, "Corrective Actio n," and other self-imposed standards.

Problem Identification: The inspectors determined that the lice nsee was effective in identifying problems and entering them into the corrective acti on program and that there was generally a low threshold for entering issues into the correcti ve action program.

Problem Prioritization and Evaluation: Based on the review of c ondition reports, the inspectors concluded that problems were prioritized and evaluat ed in accordance with the condition report significance determination guidance in procedu re PI-AA-200. Inspectors determined that adequate consideration was given to system or c omponent operability and associated plant risk. The inspectors determined that plant pe rsonnel had conducted cause evaluations in compliance with CAP procedures and that causal d eterminations were appropriate, and considered the significance of the issues bein g evaluated.

Corrective Actions: The team concluded that the licensee was ge nerally effective in developing CAs that were appropriately focused to correct the i dentified problem, and to address the root and contributing causes for significant condit ions adverse to quality, to preclude repetition. The licensee generally completed correcti ve actions in a timely manner and in accordance with procedural requirements, commensurate wi th the safety significance of the issue. For NRC-identified issues, the team determined t hat the licensee generally assigned CAs that were effective and timely.

2. Operating Experience

The licensee routinely screened industry and NRC Operating Expe rience information for station applicability, as prescribed by PI-AA-100-1007, Operati ng Experience Program. Based on these initial screenings, the licensee-initi ated actions in the CAP to fully evaluate any potential station impact. When applicable, action s were developed and implemented in a timely manner, to prevent similar issues from occurring. Operating Experience lessons-learned were communicated and incorporated i nto plant operations.

3. Self-Assessments and Audits

The inspectors determined that the licensee effectively perform ed self-assessments and audits to identify issues at a low level, properly evaluate tho se issues, and resolve them commensurate with their safety significance. Self-assessments were generally detailed and critical. The inspectors verified that corrective action docum ents were initiated to document areas for improvement and findings resulting from self-assessme nts and verified that actions had been completed consistent with those recommendations. Qual ity assurance program audits appropriately assessed performance and identified areas for improvement.

4. Safety Conscious Work Environment

Based on safety culture interviews with approximately 20 plant personnel, reviews of the latest safety culture survey results, and interviews with emplo yee concerns program (ECP)

personnel, the inspectors found no evidence of challenges to th e safety conscious work environment. Employees appeared willing to raise nuclear safet y concerns through at least one of the several means available.

Transient Combustible Stored in a Restricted Area Cornerstone Significance Cross-Cutting Report Aspect Section

Mitigating Green [P.5] - 71152B Systems NCV 05000280/2022011-01 Operating Open/Closed Experience An NRC identified finding of very-low safety significance (Gree n) and an associated Non-Cited Violation (NCV) of License Condition 3.I, Fire Protection, associated with the licensee's failure to implement and maintain in effect, the provisions of the approved fire protection program as described in the Updated Final Safety Analysis Repor t (UFSAR), which resulted in storage of a transient combustible within a restricted or co mbustion free zone.

Description: On May 12, 2022, the inspectors conducted a walkd own of the Unit 1 auxiliary building 13-foot elevation. The inspectors identified an unatt ended, partially filled, oil drum within a few feet of the Unit 1 charging pump exterior wall.

The inspectors reviewed the transient fire loading report poste d on the nearby wall. The report did not identify any flammable/combustible liquids in th e area. Additionally, in Section 2, Work Area Preparation and Precautions, it was checked to obs erve the restrictions in fire zones listed in Attachments 8 or Attachment 9 or obtain varianc e.

The inspectors reviewed CM-AA-FPA-101, Attachment 9, Surry Powe r Station Transient Combustible Loading Limits and Restrictions, which includes a r estriction for the auxiliary building general area that states, No transient within 10 ft. of exterior wall of charging pump cubicles on elev. 2 ft. and 13 ft."

The inspectors determined the unattended oil drum was located w ithin a restricted area and the station had failed to establish any variance or compensator y actions associated with a transient combustible stored within a restricted area or combus tion free zone.

Corrective Actions: On May 26, 2022, the licensee removed the oil drum from the restricted area and the licensee is reviewing additional corrective action s.

Corrective Action References: CR1200410 Performance Assessment:

Performance Deficiency: The inspectors found that the licensee s failure to implement the fire protection program in accordance with licensee procedure CM-AA-FPA-101, which resulted in the storage of a transient combustible within a restricted o r combustion free zone, was a performance deficiency within the licensees ability to foresee and prevent.

Screening: The inspectors determined the performance deficienc y was more 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 transient combusti ble was stored within a restricted or combustion free zone, which affected the zones f unction to prevent the spread of fire near the Unit 1 charging pumps. The inspectors used IM C 0612, Appendix E, Examples of Minor Issues, dated January 1, 2021, to inform an swers to the more than minor screening questions and found this condition consistent with mo re than minor Example 4.j.

Significance: The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. This finding wa s determined to be of very-low safety significance (Green) because the transient combustib le was stored in an approved

container and had a low degradation grading in accordance wit h IMC 0609, Appendix F, Attachment 2.

Cross-Cutting Aspect: P.5 - Operating Experience: The organiza tion systematically and effectively collects, evaluates, and implements relevant intern al and external operating experience in a timely manner. The inspectors found that the l icensee did not implement relevant internal operating experience related to the NRC 2nd Q uarter 2021 Green NCV due to a transient fire load incident.

Enforcement:

Violation: License Condition 3.I, Fire Protection, states in part, The licensee shall implement and maintain in effect the provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report UFSAR Section 9.10.1, Design Bases, states in part, Compliance with these criteria is conta ined in the following documents Fire Protection Program document and the associated Administrative Procedures describe the administrative and technical controls. Licensee procedure CM-AA-FPA-101, Attachment 9, Surry Power Station Transient Combustibl e Loading Limits and Restrictions, which includes a restriction for the auxiliary bu ilding general area that states, No transient within 10 ft. of exterior wall of charging pump c ubicles on elev. 2 ft. and 13 ft.

Contrary to the above, from May 12, 2022 to May 22, 2022, the l icensee failed to implement and maintain in effect, the provisions of the approved fire pro tection program as described in the UFSAR, resulting in noncompliance with the fire protection program document, CM-AA-FPA-100, and the associated administrative procedure, CM-AA-FPA -101, which describe the administrative and technical controls of transient combustibles. Specifically, the licensee stored a transient combustible within the auxiliary building re stricted or combustion free zone.

Enforcement Action: This violation is being treated as a non-c ited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Minor Violation 71152B Minor Violation: The NRC identified a minor violation of 10 CF R Part 50, Appendix B, Criterion XVI, Corrective Action. Specifically, the licensee f ailed to enter a condition adverse to quality (CAQ) associated with the auxiliary feedwater (AFW) fire main connection tell-tale drain into the corrective action program.

NRC inspectors performed a system walkdown of the AFW system for both units on May 12, 2022. The inspectors noted that the AFW fire main connection l ine to the AFW pump suction header had a tell-tale drain that was covered by a foreign mate rial exclusion (FME)

cover. The FME cover, which was not required for a vertical do wnward opening, had the potential to prevent detection of leakage from the drain. The issue was reported to station operators and the condition was promptly corrected, though a co ndition report was not entered into the CAP. The condition can reasonably be viewed a s a condition adverse to quality, and per station procedure PI-AA-200, Corrective Action, should have resulted in a condition report for the purpose of tracking and resolving the issue. Although the condition was promptly corrected, the ability to track and trend the cond ition across the station was not possible without an entry into the CAP. On May 24, 2022, the i ssue was brought up to Surry Licensing during a daily debrief for the PI&R Inspection, and a CR was entered into the CAP.

Screening: The inspectors determined the performance deficienc y was minor. The inspectors determined that this issue was minor in accordance w ith NRCs inspection manual chapter (IMC) 0612, Issue Screening, IMC 0612, App. B, Addit ional Issue Screening Guidance" and IMC 0612, App. E, Examples of Minor Issues. Sp ecifically, the performance deficiency could not be reasonably viewed as a precursor to a s ignificant event; if left uncorrected, would not have the potential to lead to a more sig nificant safety concern and did not adversely affect the mitigating systems cornerstone objecti ve.

Enforcement: The licensee initiated a CR to capture the improp er instillation of the FME cover. This failure to comply with 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action constitutes a minor violation that is not subject to enf orcement action in accordance with the NRCs Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

• On May 26, 2022, the inspectors presented the biennial problem identification and resolution inspection results to David Wilson and other members of the licensee staff.

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