IR 05000280/2023002
| ML23215A150 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 08/04/2023 |
| From: | Matthew Fannon NRC/RGN-II |
| To: | Carr E Virginia Electric & Power Co (VEPCO) |
| References | |
| IR 2023002 | |
| Download: ML23215A150 (1) | |
Text
SUBJECT:
SURRY POWER STATION - INTEGRATED INSPECTION REPORT 05000280/2023002 AND 05000281/2023002
Dear Eric S. Carr:
On June 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Surry Power Station. On July 25, 2023, the NRC inspectors discussed the results of this inspection with David Wilson, 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.
A licensee-identified violation which was determined to be of very low safety significance is documented in this report. 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 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.
August 4, 2023
Sincerely, 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:
Report Numbers:
05000280/2023002 and 05000281/2023002
Enterprise Identifier:
I-2023-002-0031
Licensee:
Virginia Electric and Power Company
Facility:
Surry Power Station
Location:
Surry, VA
Inspection Dates:
April 1, 2023, to June 30, 2023
Inspectors:
J. Bell, Senior Health Physicist
S. Campbell, Senior Reactor Systems Engineer
K. Henry, Resident Inspector
Z. Hollcraft, Senior Reactor Operations Engineer
B. Kellner, Senior Health Physicist
S. Kennedy, Senior Resident Inspector
D. Merzke, Senior Reactor Operations Engineer
D. Ray, Reactor Inspector
M. Schwieg, Senior Reactor Inspector
B. Towne, Resident Inspector
A. Wilson, Senior Project Engineer
Approved By:
Matthew S. Fannon, Chief
Reactor Projects Branch 4
Division of Reactor Projects
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. A licensee-identified non-cited violation is documented in report section: 71111.08P.
List of Findings and Violations
Non-Functional Fire Barrier Associated With Unit 1 Emergency Switchgear Room Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000280/2023002-01 Open/Closed
[P.1] -
Identification 71111.05 The NRC identified a finding of very low safety significance (Green) 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 Report (UFSAR). This resulted in a non-functional fire penetration in the Unit 1 emergency switchgear room Appendix R boundary.
Failure to Manage the Risk During 2J Emergency Bus and #3 Emergency Diesel Generator Maintenance Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000280/2023002-02 Open/Closed
[H.13] -
Consistent Process 71111.13 The NRC identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.65(a)(4) for the failure of the licensee to manage the increase in risk on Unit 1 during 2J emergency bus and #3 emergency diesel generator (EDG) maintenance. Specifically, the maintenance resulted in the unavailability of the #3 EDG to Unit 1 4160 volts alternating current (AC) 1J emergency bus. However, the licensee did not include offsite AC source breakers and the alternate AC (AAC) diesel tie breakers in the boundary of protected equipment, which resulted in the offsite AC sources and the AAC diesel not being fully protected.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 operated at or near rated thermal power (RTP) for the entire inspection period.
Unit 2 began the inspection period at RTP. On April 23, 2023, the unit was shut down for a planned refueling outage. The unit went online on June 8. On June 10, while at 27 percent power, the unit was shut down due to leak-by on a pressurizer safety valve. Following repairs, the unit was returned to RTP on June 17, 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 activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal hot temperatures for the following systems: Unit 1 and Unit 2 cable spreading rooms and the emergency diesel generators on June 28, 2023.
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather associated with a hot weather alert on June 2, 2023.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 2 low safety injection system following routine surveillance on April 20, 2023
- (2) Unit 2 residual heat removal system during plant cooldown on April 23, 2023
- (3) Unit 1 chemical and volume control system following misalignment of the boric acid transfer pump on April 24, 2024
- (4) Spent fuel pit cooling system during Unit 2 refueling outage on May 3, 2023
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 1 and Unit 2 4160 Volt AC offsite sources on May 25, 2023.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (8 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) Charging pump service water pump room (mechanical equipment room 4), elevation 9 feet - 6 inches on April 26, 2023
- (2) Unit 2 cable vault penetration area, elevation 15 feet - 0 inches on April 26, 2023
- (3) Unit 2 cable vault tunnel, elevation 9 feet - 6 inches and 15 feet - 0 inches on April 26, 2023
- (4) Fuel building, elevations 27 feet - 6 inches and 45 feet - 10 inches on April 27, 2023
- (5) Fuel building, elevations 6 feet - 10 inches and 15 feet - 10 inches on April 27, 2023
- (6) Unit 2 containment, elevations 45 feet - 4 inches, 27 feet - 7 inches, 18 feet - 4 inches, and (-) 3 feet - 6 inches on May 2, 2023
- (7) Emergency service water pumphouse, low level, elevation 18 feet on May 18, 2023
- (8) Unit 1 switchgear room, elevation 9 feet - 6 inches and the Unit 1 cable vault tunnel, elevation 9 feet - 6 inches on May 30, 2023
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated external flooding mitigation protections in the turbine building on June 22, 2023.
===71111.08P - Inservice Inspection Activities (PWR) The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from May 2, 2023, to May 18, 2023.
PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01)===
The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:
- (1) Ultrasonic examinations of the loop B intermediate leg welds
Penetrant examinations for the residual heat removal (RHR) heat exchanger integral attachment Visual examinations of the core barrel upper and lower girth welds
Visual examinations for various reactor vessel internals
Welding activities on the 6 feedwater recirculation line PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)
The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:
Condition Report (CR) 1108834, RHR heat exchanger 1B drain evaluation.
CR1206287, reserve water storage tank safety injection flow indication evaluation
Auxiliary Building walkdown PWR Inservice Inspection Activities Sample - Steam Generator Tube Inspection Activities (Section 03.04) (1 Sample)
The inspectors verified that the licensee is monitoring the steam generator tube integrity appropriately through a review of the following examinations:
- (1) Steam generator A eddy current inspection
Steam generator B eddy current inspection
Steam generator C eddy current inspection
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 assessed licensed operator performance in the control room during Unit 2 shutdown to hot shutdown conditions on April 23, 2023.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated just-in-time training in the simulator in preparation for Unit 2 startup following refueling outage on May 17, 2023.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 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 and Unit 2 elevated risk due to 1-FP-P-2B, diesel-driven fire pump, out of service for maintenance on April 5, 2023
- (2) Alternate AC diesel out of service due to high jacket water temperature alarm on April 5, 2023
- (3) Unit 2 shutdown risk plan in preparation for 2R31 Outage on May 2, 2023
- (4) Unit 2 shutdown risk assessment following full core offload to spent fuel pool on May 5, 2023
- (5) Unit 1 elevated risk due to 2J 4160 volts AC bus out of service for maintenance on May 11, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) CR1223548, 2-RM-RI-218/219, Unit 2 letdown radiation monitors, alert/failure during thunderstorm/lighting conditions on April 6, 2023
- (2) CR1223809 Differential pressure for 2-RM-RI-259/260, Unit 2 particulate radiation sampler found low out of specification on April 11, 2023
- (3) CR1228406, 1-SW-P-1C, Emergency service water pump, margin to biofouling less than 350 gallons per minute on May 14, 2023
- (4) CR1228097, Corrosion identified on component cooling line in Unit 2 containment on May 11, 2023
- (5) CR1229000, 1A-G3 alarm cleared while draining 1-SI-P-1A, A low head safety injection pump, on May 21, 2023
- (6) CR1229624, Loop B bypass stop valve, difficult to operate on May 29, 2023
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (2 Samples)
- (1) The inspectors evaluated Unit 2 refueling outage 2R31 activities from April 23, 2023, to June 8, 2023.
- (2) The inspectors evaluated Unit 2 forced outage due to seat leakage identified on the B pressurizer safety valve from June 10, 2023, to June 14, 2023.
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (7 Samples)
(1)1-PT-18.8A, Charging Pump Component Cooling Pump Performance, after motor cleaning and inspection of Unit 1 charging pump component cooling pump 2B on April 3, 2023 (2)0-MCM-0419-06, Unit 2 Power Operated Pressure Relief Valve Inspect and Overhaul, on May 10, 2023 (3)2-EPM-1817-02, Protective Relay Maintenance for Circuit Breaker 25J5 Charging Pump 1B on May 13, 2023 (4)2-PT-18.8, Charging Pump Service Water Performance, after repair of high differential pressure on 2-SW-P-10B, Unit 2 charging pump service water pump, on May 14, 2023
- (5) CAL-047, Nuclear Instrumentation Source Range Drawer, following replacement of N32, Unit 2 source range instrument, pre-amplifier on May 25, 2023 (6)2-OPT-FW-003, Turbine Driven Auxiliary Feedwater Pump Test, after repair of inboard pump bearing leaks on June 7, 2023 (7)2-PT-11, Reactor Pressure Test, following replacement of the RC-2551B, B PZR safety valve on June 14, 2023
Surveillance Testing (IP Section 03.01) (3 Samples)
(1)2-IPT-CC-P-403, Reactor Coolant System Pressure Loop P-403 Calibration, on April 4, 2023 (2)0-OPT-EG-001, Number 3 EDG Test - Monthly, on May 15, 2023 (3)2-OPT-RH-003, Residual Heat Removal System Operability Test, on May 26, 2023
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
(1)1-OPT-RS-007, Containment Outside Recirculation Spray Pumps Motor Operated Valve Stroke Test, on April 6, 2023
Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)
(1)2-OPT-CT-201, Containment Isolation Valve Local Leak Rate Testing (Type C Containment Testing), on May 25,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Workers exiting the Unit 2 containment Contaminated Area (CA) during outage
- (2) Workers exiting the auxiliary building radiological controlled area (RCA) during outage
- (3) Boxes of radioactive materials brought into and stored in Unit 2 containment during outage
Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (1) Scaffold building in 'B' reactor coolant pump Locked High Radiation Area (LHRA)
- (2) Reactor upper internals lift
- (3) Fuel movement
- (4) Spent primary resin transfer to High Integrity Container (HIC)
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) Unit 1 volume control tank room Locked High Radiation Area (LHRA)
- (2) Units 1 and 2 ion exchanger alley LHRA
- (3) Unit 1 primary drain tank gas stripper LHRA
- (4) Unit 2 letdown regen heat exchanger room LHRA
- (5) Unit 2 'B' loop room LHRA Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01)
The inspectors evaluated the licensees performance in controlling, labeling and securing the following radioactive materials:
- (1) Surry Radwaste Facility (SRF) and SRF yard (Category 2 storage located outside the Protected Area fence).
- (2) Low Level Radioactive Waste Storage Building (located outside the Protected Area fence)
- (3) Steam Generator Mausoleum (Category 2 storage location located outside the Protected Area fence)
Radioactive Waste System Walkdown (IP Section 03.02) (3 Samples)
The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:
- (1) Spent Resin Tank and Spent Resin Batching Tank and transfer system (located in the auxiliary building)
- (2) Liquid Waste Evaporator System (located in the SRF)
- (3) Liquid Radwaste Reverse Osmosis System, including filter media processing (Thermex System located in the SRF)
Waste Characterization and Classification (IP Section 03.03) (3 Samples)
The inspectors evaluated the following characterization and classification of radioactive waste:
- (1) Surry 2021 Dry Active Waste (DAW) Part 61 Characterization (Sample # L93876-6)
- (2) Surry LCS Resin Part 61 Characterization (Sample # L93877-1)
- (3) Surry 1-CH-FL-2 (RCS Filter) Part 61 Characterization (Sample # L98118-1)
Shipment Preparation (IP Section 03.04) (1 Sample)
- (1) Observed preparation, loading, and survey of shipment number D2023-12 (SCO shipment of two sealand boxes of radioactive waste going to an offsite waste processor facility)
Shipping Records (IP Section 03.05) (4 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
- (1) Shipment number: D2023-4 [Two sealand boxes shipped UN3321, LSA-II (Non-refriable asbestos roofing debris going to an offsite waste processor facility)]
- (2) Shipment number: SV2023-1 [UN2916 Type B(U) package shipped as Yellow-III, Exclusive Use (mixed bed resin in a HIC going to an offsite waste processor facility)]
- (3) Shipment number: SV2021-1 [UN2916 Type B(U) package shipped as Yellow-III, Exclusive Use (mixed bed resin in a HIC going to an offsite waste processor facility)]
- (4) Shipment number: D2022-13 [Two sealand boxes shipped UN3321, LSA-II (Dry Active Waste (DAW) going to an offsite waste processor facility)]
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15)===
- (1) August 2, 2022, to May 1, 2023 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) August 1, 2022, to May 1, 2023
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective actions program and related documents such as trend reports, licensee performance indicators, and system health reports for potential adverse trends that might be indicative of a more significant safety issue.
INSPECTION RESULTS
Non-Functional Fire Barrier Associated With Unit 1 Emergency Switchgear Room Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000280/2023002-01 Open/Closed
[P.1] -
Identification 71111.05 The NRC identified a finding of very low safety significance (Green) 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 Report (UFSAR). This resulted in a non-functional fire penetration in the Unit 1 emergency switchgear room Appendix R boundary.
Description:
On May 30, 2023, the inspectors performed a walkdown of the Unit 1 switchgear room, Fire Area 3, elevation 9 feet - 6 inches and the Unit 1 cable vault tunnel, Fire Area 2, elevation 9 feet - 6 inches. The inspectors identified a penetration on the wall between the switchgear room and cable vault tunnel that did not appear to be completely sealed. The sites Engineering staff determined that the penetration had insufficient depth of fire-retardant material. Engineering determined that the depth of the fire-retardant material was 8.75 inches which did not meet the requirements of ECM-0901-02, Opening and Sealing of Fire Barriers. ECM-0901-02 stated that the vendors required fire-retardant material depth is 10 - 12 inches.
CM-AA-FPA-100, Fire Protection/Appendix R (Fire Safe Shutdown) Program, states that the penetration must provide equal or greater fire rating than that of the fire barrier. The fire rating of the wall between the Unit 1 switchgear room and the Unit 1 cable vault tunnel is 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
Engineering determined that the fire barrier rating was 2 to 2 1/2 hours in the degraded as-found condition.
As a result, Operations declared the penetration non-functional and established an hourly fire watch in accordance with Technical Requirements Manual (TRM) 3.7.8. In addition to the fire watch, TRM 3.7.8 required that the penetration be restored to an operable condition within 7 days.
The licensee determined that the installation of the cable and penetration occurred in 2014 and that inspection of the penetrations are performed every 5 years. The last inspection was performed in 2019 and the licensee documented that the penetration met the acceptance criteria. The licensee did not assign a review to determine the cause since the personnel involved in the original installation of the penetration are no longer working at the site and a review would not have conducive results. Based on the as-found condition of the penetration (the penetration did not appear completely sealed) on May 30, 2023, the inspectors concluded this issue most likely occurred during the installation process in 2014 and not identified during the periodic inspection in 2019.
Corrective Actions: In addition to declaring the penetration non-functional and entering the associated TRM action statement, the licensee repaired the penetration and initiated a corrective action to perform an extent of condition walkdown of fire penetrations.
Corrective Action References: CR1229721, CA11976842, CA11976844
Performance Assessment:
Performance Deficiency: During the initial installation of the fire barrier in 2014, the licensee failed to ensure that the penetration seal met the requirements of licensee procedure CM-AA-FPA-100. This performance deficiency resulted in a degraded fire penetration, which was 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 Protection Against External Factors 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 vendor specification for the depth of fire-retardant material was not met and the as left condition could have impacted the ability of the penetration to function as a 3-hour fire rated barrier. The inspectors used Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues, dated January 1, 2021, to inform answers to the more than minor screening questions and found this condition consistent with more than minor example 2.d.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The finding was determined to be of very low safety significance (Green) because there is adequate automatic suppression on either side of the fire confinement element in accordance with IMC 0609, Appendix F, Attachment 1, Step 1.4.4: Fire Confinement, Question 1.4.4-B.
Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. Specifically, the licensee did not implement a corrective action program with a low threshold for identifying issues when the penetration was last inspected in 2019. The inspectors determined that this was reflective of current performance since the last fire penetration inspection was completed in 2019 and there have been no other opportunities to show that the performance characteristic had been corrected.
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 contained in the following documents Fire Protection Program documents and the associated Administrative Procedures describe the administrative and technical controls. Licensee procedure CM-AA-FPA-100, Fire Protection/Appendix R (Fire Safe Shutdown) Program, states, in part, Penetration must provide equal or greater fire rating than that of the fire barrier.
Contrary to the above, from approximately 2014 to May 30, 2023, the licensee failed to implement and maintain in effect, the provisions of the approved fire protection program as described in the UFSAR, resulting in noncompliance of fire penetration rating requirements as documented in CM-AA-FPA-100. Specifically, the licensee did not ensure that a new fire penetration seal established in 2014 between the Unit 1 switchgear room and cable vault tunnel contained sufficient fire-retardant material to provide a fire rating equal to or greater than that of the fire barrier.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Licensee-Identified Non-Cited Violation 71111.08P This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: A violation of 10 CFR 50. 55a(b)(5), "Conditions on inservice inspection Code Cases," was identified by the licensee. Periodic program updates are required in accordance with Code Case N-716-1 and the fifth
- (5) interval third
- (3) period program update was not performed.
Significance/Severity: Green. The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, including Exhibit 2, "Mitigating Systems Screening Questions." The violation screened as having very low safety significance (Green) because the inspectors answered all Mitigating Systems Screening Questions as "no." Additionally, the Code Case program update was performed and there were no significant changes required to the current inservice program.
Corrective Action References: CR1222209, SPS2 RI-ISI periodic update not completed in timely manner Failure to Manage the Risk During 2J Emergency Bus and #3 Emergency Diesel Generator Maintenance Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000280/2023002-02 Open/Closed
[H.13] -
Consistent Process 71111.13 The NRC identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.65(a)(4) for the failure of the licensee to manage the increase in risk on Unit 1 during 2J emergency bus and #3 emergency diesel generator (EDG) maintenance. Specifically, the maintenance resulted in the unavailability of the #3 EDG to Unit 1 4160 volts alternating current (AC) 1J emergency bus. However, the licensee did not include offsite AC source breakers and the alternate AC (AAC) diesel tie breakers in the boundary of protected equipment, which resulted in the offsite AC sources and the AAC diesel not being fully protected.
Description:
On May 08, 2023, the licensee placed the 2J emergency bus and #3 EDG out of service to perform planned maintenance during the Unit 2 refueling outage. The evaluated risk for this activity was an elevated green condition for Unit 1, the operating unit. The loss of electrical offsite and/or emergency alternating current power sources could result in a high-risk condition, loss of core cooling, or limiting Technical Specification action statements. The licensee exited the maintenance activity on May 12, 2023.
On May 11, 2023, the inspectors reviewed the stations daily risk assessment and performed a walkdown of the posted equipment to ensure the risk management actions were properly implemented. The inspectors noted that the breakers (15D1, 15F1, and 15H8) from the reserve service station transformers (RSSTs) A and C to the transfer busses and from the transfer busses to the emergency busses were not protected. After further walkdowns, the inspectors noted that the tie breakers (05L1, 05L2, and 05L3) connecting the AAC diesel to the D and E transfer busses were not protected although Operations had authorized work adjacent to the breakers. The RSSTs and the AAC diesel were listed as protected equipment.
However, the associated offsite AC source breakers and the AAC diesel tie breakers, which were in other areas of the plant, were not similarly listed as protected equipment. The concern was that the licensee could have and did authorize inappropriate work in the areas which could result in the loss of the redundant sources available to the Unit 1 emergency 4160 Volt AC busses.
The licensee maintains operator aids (protected equipment posting sheets) for risk-significant equipment placed out of service for maintenance as a risk management action (RMA). The aid contains a list of components required to be protected to mitigate the risk of the equipment of service. The inspectors reviewed the operator aid for the 2J Emergency Bus and #3 EDG maintenance and noted that the offsite AC source breakers and the AAC diesel tie breakers were not included on the aid. The inspectors concluded, and the licensee agreed, that it was appropriate to protect offsite AC source breakers and the AAC diesel tie breakers during the 2J bus dead bus outage and #3 EDG maintenance.
Corrective Actions: The licensee entered this issue into the Corrective Action Program and is evaluating RMAs for protected equipment by the establishment of protected trains, reviewing the protected equipment posting sheets for adequate scope, and formally incorporating the protected equipment posting sheets into their protected equipment procedure.
Corrective Action References: CR1228106
Performance Assessment:
Performance Deficiency: The licensee failed to adequately assess and manage the risk, in accordance with 10 CFR 50.65(a)(4), that resulted from maintenance activities associated with the 2J emergency bus and the #3 EDG. Specifically, the RMAs for the activity did not include the breakers connecting the offsite AC sources and the AAC diesel to the emergency busses in the protected equipment boundary, which resulted in the offsite AC sources and AAC diesel not being fully protected. This performance deficiency was within the licensee's ability to foresee and prevent.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Configuration 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 failure to include the breakers in the protected equipment boundary for the 2J emergency bus and #3 EDG maintenance could result in inappropriate work in the area and the loss of offsite sources and/or the AAC diesel for safe operations of the plant. The inspectors used IMC 0612, Appendix E, Examples of Minor Issues, dated January 1, 2021, to inform answers to the more than minor screening questions and found this condition consistent with more than minor example 8.f.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix K, Maintenance Risk Assessment and Risk Management SDP. A regional Senior Reactor Analyst calculated incremental core damage probability (ICDP) for the maintenance using SAPHIRE 8 Version 8.2.6 and the Surry Units 1 & 2 SPAR model version 8.80 dated May 26, 2022. The maintenance activity was modeled as the 2J 4160 volts AC switchgear inoperable due to Test and Maintenance and a conservative exposure period of 14 days was assigned. Both the operating unit (Unit 1) and the outage unit (Unit 2) were considered. Unit 1 was in mode 1 and 100 percent power so an ICDP was calculated using the SPAR model. The dominate accident sequence was a failure of the 1H 4160 volts AC switchgear, a common cause failure of all Unit 1 and 2 auxiliary feedwater to run, and power-operated relief valve (PORV) Block Valve 1535 being closed. ICDP was less than 10-7 thus the incremental large early release probability (ILERP) was also less than 10-7.
Unit 2 was in no mode with fuel off loaded to the spent fuel pool (SFP) and the reactor cavity flooded and in communication with the SFP. The licensees qualitative shutdown risk assessment determined SFP cooling risk was green due to multiple trains of SFP cooling and residual heat removal available. Referring to IMC 0609 Appendix G, in this configuration due to the significant volume of coolant available and multiple trains of cooling available, the SRA qualitatively determined that ICDP would be less than 10-6 and ILERP less than 10-7.
Because the performance deficiency was related to inadequate RMAs, the inspectors were directed to IMC 0609 Appendix K Flowchart 2, Assessment of RMAs. The inspectors determined the finding screened to very low safety significance (Green) since ICDP was less than 10-6 and ILERP was less than 10-7 for both units.
Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic approach to make decisions. Risk insights are incorporated as appropriate. The inspectors found that the licensee used an informal process to determine RMAs when protecting risk-significant equipment during maintenance activities. The RMA determination process did not have the benefits of being vetted, reviewed, or revision controlled and as such was subject to potential error.
Enforcement:
Violation: 10 CFR 50.65(a)(4) "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," states, in part, that before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities.
Contrary to the above, between May 08, 2023, and May 12, 2023, the licensee failed to manage the increase in risk during the 2J 4160 volts AC emergency bus and #3 EDG maintenance. Specifically, the licensee did not include the Unit 1 AC offsite source breakers and the AAC diesel tie breakers in the protected equipment boundary for the 2J Emergency Bus and #3 EDG maintenance, which resulted in the AAC diesel and offsite AC sources not being fully protected.
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 July 25, 2023, the inspectors presented the integrated inspection results to David Wilson, Site Vice President, and other members of the licensee staff.
On May 4, 2023, the inspectors presented the radiation protection occupational &
transportation inspection results to David Wilson, Site Vice President, and other members of the licensee staff.
On May 18, 2023, the inspectors presented the Unit 2 inservice inspection results to David Wilson, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR1222209
SPS2 RI-ISI periodic update not completed in timely manner
- ISI Self-
Assessment
03/31/2023
Miscellaneous
PRA Input to Surry Unit 1 RI-ISI Program
Procedures
ER-AA-ISI-RI-101
The Dominion Risk Informed Period Update Process
Protected Equipment
Procedures
OP-SU-601
Protected Equipment
0-OPT-SW-003
Emergency Service Water Pump 1-SW-P-1C
Procedures
Corrective Action
Documents
CR 1221450
A Quality Control (QC) Check on Tri-Carb 3100TR was not
performed prior to counting samples.
03/10/2023
Radioactive Material Control Program
Rev. 5
Radiological Posting
Rev. 13
Radiation Surveys
Rev. 3
Procedures
Contamination Surveys
Rev. 4
Unit 2 containment reactor cavity survey
04/24/2023
Radiation
Surveys
Unit 2 containment in-core sump room survey
04/23/2023
Corrective Action
Documents
CR1176556, CR1179296, CR1184182, and CR1197277
Various
Engineering
Evaluations
9168
Model 8-120B package Certificate of Compliance (COC) for
radioactive material packages [Docket # 71-9168, Package
ID # USA/9168/B(U)-96]
Revision 25
21 Surry Annual Radioactive Source Inventory and Semi-
Annual Source leak Test Data [C-HP-1071.01 Attachment 3,
Sources Requiring Leak Testing and Attachment 4, Sources
Not Requiring Leak Testing]
08/11/2021
National Source Tracking System (NSTS) Inventory
Verification/Reconciliation for CY 2022 and 2023
Various
Miscellaneous
22 Surry Annual Radioactive Source Inventory and Semi-
Annual Source leak Test Data [C-HP-1071.01 Attachment 3,
Sources Requiring Leak Testing and Attachment 4, Sources
Not Requiring Leak Testing]
08/31/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
C-HP-1071.010
Control of Radioactive Sources
Revision 8
Procedures
VPAP-2104
Radioactive Waste Process Control Program (PCP)
Revision 8
Audit 22-06
Radiological Protection, Process Control Program, and
Chemistry
09/19/2022
Self-Assessments
CA9212347
Surry Solid Radioactive Waste Control Program Review, 3rd
Quarter 2019-2nd Quarter 2022 (September 2019-April
22)
07/28/2022
Corrective Action
Documents
CR1210521, CR1210521, CR1217009, CR1217239, and
CR1218540
Various
23 Gas-Release and Dose Summary Report [01/01/2023
to 5/05/01/2023]
05/01/2023
23 Liquid-Release and Dose Summary Report
[01/01/2023 to 5/05/01/2023]
05/01/2023
Surry Power Station Radiological Protection Monthly
Performance Indicator Assessments - August 2022 thru
February 2023
Various
G-20221222-384-
C
Ventilation Vent #2 Gaseous Radioactive Waste Release
Permit - End Date: 1/1/2023 00:00 [including monthly,
quarterly, and annual dose summaries]
01/01/2023
71151
Miscellaneous
L-20221227-288-
B
Waste Monitoring Tank A Liquid Radioactive Waste Release
Permit - End Date: 12/27/2022 12:35 [including monthly,
quarterly, and annual dose summaries]
2/29/2022