IR 05000280/2023004
| ML24043A079 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 02/09/2024 |
| From: | Matthew Fannon NRC/RGN-II/DRP/RPB4 |
| To: | Carr E Virginia Electric & Power Co (VEPCO) |
| References | |
| IR 2023004 | |
| Download: ML24043A079 (16) | |
Text
SUBJECT:
SURRY POWER STATION - INTEGRATED INSPECTION REPORT 05000280/2023004 AND 05000281/2023004
Dear Eric S. Carr:
On December 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Surry Power Station. On January 24, 2024, 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.
February 9, 2024 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, 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:
05000280/2023004 and 05000281/2023004
Enterprise Identifier:
I-2023-004-0031
Licensee:
Virginia Electric and Power Company
Facility:
Surry Power Station
Location:
Surry, VA
Inspection Dates:
October 01, 2023 to December 31, 2023
Inspectors:
M. Donithan, Senior Operations Engineer
D. Jung, Resident Inspector
S. Kennedy, Senior Resident Inspector
M. Meeks, Senior Operations Engineer
M. Schwieg, Senior Reactor Inspector
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: 71152A.
List of Findings and Violations
Non-functional Fire Barrier associated with Unit 1 Cable Tray Room
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
[H.1] -
Resources
The inspectors 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), which
resulted in non-functional fire penetrations in the Unit 1 cable tray room.
Failure to Effectively Monitor Maintenance Rule Scoped Components
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000280,05000281/2023004-02
Open/Closed
[P.2] -
Evaluation
The inspectors identified a finding of very low safety significance (Green) and associated non-
cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.65(a)(2) for
failure to demonstrate effective control of the performance of maintenance rule scoped
components through appropriate preventive maintenance. Specifically, the licensee failed to
monitor performance of the 96-inch circulating water expansion joint spray shields, in
accordance with their preventive maintenance program and did not implement (a)(1) goals
and corrective actions.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 operated at or near rated thermal power for the entire inspection period.
Unit 2 operated at or near rated thermal power for the entire 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 DProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 2515,</br></br>Appendix D" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., 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 cold temperatures for the following systems:
refueling water storage tanks
emergency diesel generators (EDGs)
fire protection system
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1)
1-VS-E-4B, '4B' main control room chiller, following repair on November 27, 2023
(2)
Unit 1 auxiliary feedwater system following completion of 1-OPT-FW-003, Steam
Driven Auxiliary Feedwater Pump 1-FW-P-2 Performance Test, on November 29,
2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (1 Sample)
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)
Unit 1 cable tray room, fire zone 46, elevation 45 feet - 3 inches, on October 16,
2023
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
(1)
The licensee completed the annual requalification operating examinations required to
be administered to all licensed operators in accordance with Title 10 of the Code of
Federal Regulations 55.59(a)(2), "Requalification Requirements," of the NRC's
"Operator's Licenses." The inspector performed an in-office review of the overall
pass/fail results of the individual operating examinations, and the crew simulator
operating examinations in accordance with Inspection Procedure (IP) 71111.11,
"Licensed Operator Requalification Program and Licensed Operator Performance."
These results were compared to the thresholds established in Section 3.03,
"Requalification Examination Results," of IP 71111.11.
The inspectors evaluated the licensed operator examination failure rates for the
requalification annual operating examinations completed on March 17, 2023.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2
Samples)
(1)
The inspectors observed and evaluated licensed operator performance in the control
room during the performance of 1-PT-25.1, Quarterly Testing of Condensate and
Service Water System Valves, on November 13, 2023.
(2)
The inspectors observed and evaluated licensed operator performance in the control
room during the performance of 0-OP-VS-006, Control Room and Relay Room
Ventilation System on November 27, 2023, and 0-OPT-VS-001, Main Control Room
A/C System Pump and Valve In-service Testing, on December 19, 2023.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1)
The inspectors observed licensed operator requalification training involving scenarios
which included a loss of chemical and volume control system letdown during grid
instability and a loss of coolant accident outside of containment on October 12, 2023.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (5 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components (SSCs) remain capable of performing their intended
function:
(1)
Unit 1 and Unit 2 circulating water system spray shield maintenance practices
(condition report [CR] 1231640)
(2)
Unit 1 1-VS-E-4B, '4B' main control room chiller reliability (CR1210646, CR1210932,
CR1211314, CR123428, CR1214802, CR1221869, CR1224811, CR1225502,
CR1225718, CR1240870, and CR1242640)
(3)
Canal level probes reliability (CR1236508, CR1236724, CR1237102, CR1238870,
and CR1240613)
(4)
Control room isolation dampers reliability (CR12300047, CR1230765, CR1233787,
CR1238582, CR1241210, and CR1241731)
(5)
2-IA-C-4A, Unit 2 containment instrument air compressor reliability (CR1238454,
CR1235314, CR1236542, and CR1237897)
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 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 emergent risk assessment due to failure of 01-VS-E-4B, '4B' control
room chiller, and service water leak from 01-VS-P-1C, control and relay room chiller
condenser '4C' service water pump, on October 18, 2023
(2)
Unit 1 and Unit 2 elevated risk during #1 EDG surveillance on December 4, 2023
(3)
Unit 1 and Unit 2 emergent risk assessment due to #2 EDG declared inoperable as a
result of battery voltage below operability threshold on December 13, 2023
(4)
Unit 1 and Unit 2 elevated risk assessment during performance of 0-OPT-VS-001,
Main Control Room Air Conditioning System Pump and Valve Inservice Testing, and
switchyard 500 kilovolts line switching on December 19, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1)
CR1240848, Unit 1 containment area radiation monitor (high range) annunciator 0-
RMA-A1, in containment high radiation alert/trouble, received on October 18, 2023
(2)
CR1240698, #2 EDG fuel oil pressure trouble on initial engine start on October 16,
2023
(3)
CR1242190, 2-SW-FI-205B, recirculation heat exchangers B and C service water
supply flow, declared non-functional on October 29, 2023
(4)
CR1245002, 2-CH-P-210B, '2B' charging pump auxiliary oil pump, was found cycling
on and off on November 29, 2023
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1
Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1)
Design equivalent change package SU-23-00122, Modify Lower Bearing Drip Pan, on
December 28, 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)
0-ECM-0901-02, Opening and Sealing of Fire Barriers, following repair of Unit 1 cable
tray room penetrations on September 28, 2023 (work order [WO] 38204336276)
(2)
Post installation inspection following sealing gap along northwest corner of wall Unit 1
cable tray room and mechanical equipment room #1 on September 28, 2023
(3)
Visual leak inspection following the repair of service water leak from 01-VS-P-1C,
control and relay room chiller condenser '4C' service water pump, on October 18,
2023 (WO38204337198)
(4)
Post repair inspection following 1-VS-MOD-103A, control room supply isolation
damper, repair on November 2, 2023 (WO38204233951)
(5)
0-MPM-1900-02, Flood Protection Backflow Preventer Testing and Installation,
following semi-annual flood protection planned maintenance on November 2, 2023
(6)
Post repair inspection following Unit 1 1-VS-E-4B, '4B' main control room chiller,
instrumentation tubing relocation on December 14, 2023 (WO38204321174)
(7)
1-IPM-SI-L-920, SI Accumulator Tank 1-SI-TK-1A Level Loop L-1-920 Calibration,
following 'A' safety injection accumulator level channel 1 indicator repair on December
28, 2023 (WO38204339057)
Surveillance Testing (IP Section 03.01) (1 Sample)
(1)
0-OPT-VS-001, Main Control Room Air Conditioning System Pump and Valve
Inservice Testing, on December 19, 2023
Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)
(1)
0-MPM-1960-01, Semi-Annual or Annual Test of Beyond Design Bases (BDB)
Diverse and Flexible Coping Strategies Equipment, BDB auxiliary feedwater pump
'2C', on November 14, 2024
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
(1)
The inspector observed and evaluated the conduct of a simulator-based licensed
operator requalification training evolution involving a steam generator tube rupture
resulting in an Alert declaration on October 24, 2023.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)
(1)
Unit 1: October 2022 through June 2023
(2)
Unit 2: October 2022 through June 2023
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
(1)
Unit 1: October 2022 through June 2023
(2)
Unit 2: October 2022 through June 2023
71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1)
Evaluation of Unit 1 cable tray room configuration for design adequacy and regulatory
compliance on December 14, 2023 (CA11362707)
(2)
Evaluation of the EDGs' protection against the effects of tornado-generated
differential pressure (CR1219861, CR1237702, CR1247481, CA11199376, and
CA12149255)
71152S - Semiannual Trend Problem Identification and Resolution
Semiannual Trend Review (Section 03.02) (1 Sample)
(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 Cable Tray Room
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
[H.1] -
Resources
The inspectors 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 UFSAR, which resulted in non-functional fire
penetrations in the Unit 1 cable tray room.
Description: On September 27, 2023, the inspectors performed a walkdown of the Unit 1
cable tray room, Fire Zone 46, elevation 9 feet - 6 inches. The inspectors identified three
penetrations on the wall between the Unit 1 cable tray room and the #1 mechanical
equipment room that did not appear to be completely sealed. ECM-0901-02, Opening and
Sealing of Fire Barriers, stated that the vendors required fire-retardant material depth is 10 -
12 inches. The sites Engineering staff determined that the depth of the fire-retardant material
was slightly less than 10 inches and contained voids and gaps.
CM-AA-FPA-100, Fire Protection/Appendix R (Fire Safe Shutdown) Program, states that
penetration seals must provide equal or greater fire rating than that of the fire barrier. The fire
rating of the fire barrier wall between the Unit 1 cable tray room and the #1 mechanical
equipment room is three hours. Engineering determined that the fire barrier would not meet
the three-hour requirement due to the degraded as-found condition of the penetrations.
As a result, Operations declared the fire barrier wall between the Unit 1 cable tray room and
the #1 mechanical equipment room 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 penetrations be restored to a functional condition within seven
days.
The installation of the cables and penetrations occurred during a turbine control system
project from October 2022 to March 2023. The licensee determined that cable penetrations
were opened and originally sealed properly per 0-ECM-0901-02. However, the cables for the
project were coiled next to the penetration during cure time of the penetrations and not yet
placed in the cable tray. Following the completion of the cure time the cable installation
continued. This moved the cables from the resting position in the penetration foam, allowing
gaps and voids to form. The voids and gaps caused the depth of the fire-retardant material to
not meet the standard.
Corrective Actions: In addition to declaring the penetration non-functional and entering the
associated TRM action statement, the licensee conducted a human performance review and
initiated a corrective action assignment to update the procedure guidance for an additional
inspection if the cables are moved following final acceptance of the penetration.
Corrective Action References: CR1239083
Performance Assessment:
Performance Deficiency: The inspectors found that the licensees failure to implement the fire
protection program in accordance with licensee procedure CM-AA-FPA-100, which resulted
in degraded fire penetrations, is a performance deficiency 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 would have impacted the ability of the
penetration to function as a three-hour fire rated barrier. The inspectors used IMC 0612,
Appendix EProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0612,</br></br>Appendix E" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., 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 FProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609</br></br>Appendix F" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., 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 FProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix F" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Attachment 1, Step 1.4.4: Fire Confinement, Question 1.4.4-B.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment,
procedures, and other resources are available and adequate to support nuclear safety.
Specifically, the procedures used for sealing the fire barrier penetrations did not have
guidance for final inspection after the cable was moved within a cable tray, conduit, or
terminated.
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 seals must provide equal or greater fire rating than that of the fire barrier.
Contrary to the above, from approximately October 2022 through September 27, 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 with fire
penetration rating requirements as documented CM-AA-FPA-100. Specifically, the licensee
did not ensure that three fire penetration seals established on the fire barrier wall between the
Unit 1 cable tray room and the #1 mechanical equipment room, 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.
Failure to Effectively Monitor Maintenance Rule Scoped Components
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000280,05000281/2023004-02
Open/Closed
[P.2] -
Evaluation
The inspectors identified a finding of very low safety significance (Green) and NCV of 10 CFR 50.65(a)(2) for failure to demonstrate effective control of the performance of maintenance rule
scoped components through appropriate preventive maintenance. Specifically, the licensee
failed to monitor performance of the 96-inch circulating water expansion joint spray shields, in
accordance with their preventive maintenance program and did not implement (a)(1) goals
and corrective actions.
Description: Each of the 96-inch circulating water inlet, intermediate outlet, and outlet
expansion joints is enclosed by a removable flow restriction shield. These spray shields act
as a passive flow restraint to limit water flowrate in the event of a ruptured expansion joint.
On June 22, 2023, the inspectors performed a walkdown of flood protection measures in the
Units 1 and 2 turbine building. During the walkdown, the inspectors identified gasket material
that was loose and hanging from between the spray shield and the lower flange on the 2-CW-
REJ-201D, condenser water box circulating water pump outlet expansion joint. The licensee
determined that the gasket material was loose because the gap between the spray shield and
the lower flange was excessive and did not meet the acceptance criteria for gap size. The
license established a flood watch, conducted a repair of the spray shield, and entered the
issue into their corrective action program as CR1231640.
The inspectors reviewed the licensee's evaluation of CR1231640 to ascertain the cause of
the excessive gap measurement and to follow up on the licensees extent of condition review
and maintenance practices associated with circulating water system spray shields. The
licensee determined that the mostly likely cause of the excessive gap between the spray
shield and lower flange was thermal movement/expansion as the condenser is in service. The
licensees corrective actions included procedurally adding a buffer zone to account for
potential spray shield expansion that could occur during the 18-month period between
inspections of the circulating water system expansion joints and measuring the gap on the
remaining circulating water spray shields to determine any extent of condition.
The inspectors determined that the licensee did not implement the requirements of ER-AA-
MRL-100, Implementing Maintenance Rule. ER-AA-MRL-100, Attachment 6, Performance
Monitoring Information, Section 2.1.6, Reliability Non-Risk Significant Functions, states, A
measure of the expectation (assuming that the SSC is available), is that the SSC will perform
its function upon demand at any future instant in time. A failure of an SSC within a non-risk
significant function is an indicator of reliability which may require further evaluation for (a)(1).
The inspectors identified that the licensee did not have a maintenance activity in place to
ensure that the spray shield would function upon demand at any future instant. Specifically,
the licensee did not have an action in place to evaluate the validity of the buffer zone to
ensure that the as-left gap would not expand above the design value prior to the next
circulating water system expansion joint inspection activity. Alternatively, the licensee did not
have an activity in place such as as-found gap measurements, periodic measurements, or
walkdowns, to verify that the gap would not expand beyond the design value. In addition, the
inspectors identified that the licensee did not evaluate if the circulating water system
maintenance rule function CW008, To provide a means to minimize out leakage should a
circulating water expansion joint fail (spray shield), require further evaluation for (a)(1). This
issue could result in licensee not being aware of the spray shields being non-functional until a
flooding event due to expansion joint failure occurs.
Corrective Actions: The licensee entered the issue into their corrective action program for
further evaluation.
Corrective Action References: CR1248766
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to implement
the requirements of ER-AA-MRL-100, Implementing Maintenance Rule, Revision 15, was a
performance deficiency reasonably 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 Equipment Performance 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, due to a lack of monitoring of the circulating water
expansion joint spray shields, the licensee failed to demonstrate that the performance of the
system is being effectively controlled through maintenance. This could result in the licensee
not being aware of the spray shields being non-functional until a flooding event due
expansion joint failure occurs. The condition is similar to the Inspection Manual Chapter 0612
Appendix EProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0612</br></br>Appendix E" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. more than minor Example 8.g.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix AProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609</br></br>Appendix A" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., The Significance Determination Process (SDP) for Findings At-Power. Using
Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening
Questions, Section A, the screening questions, were all answered as NO; therefore, the
inspectors determined the finding was of very low safety significance (Green).
Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to
ensure that resolutions address causes and extent of conditions commensurate with their
safety significance. Specifically, resolutions did not fully address the cause of thermal
expansion to satisfy the expectation that the SSC will perform its function upon demand at
any future instant in time.
Enforcement:
Violation: 10 CFR 50.65(a)(1), requires, in part, each holder of an operating license for a
nuclear power plant under this part shall monitor the performance or condition of structures,
systems, or components, against licensee-established goals, in a manner sufficient to provide
reasonable assurance that these structures, systems, and components, as defined by 10 CFR 50.65(b), are capable of fulfilling their intended functions. 10 CFR 50.65(a)(2), requires,
in part, that monitoring as specified in 10 CFR 50.65(a)(1) is not required where it has been
demonstrated that the performance or condition of a structure, system, or component is being
effectively controlled through the performance of appropriate preventive maintenance, such
that the structure, system, or component remains capable of performing its intended function.
Contrary to the above, prior to January 19, 2024, the licensee failed to effectively monitor the
performance or condition of a structure, system, or component through the performance of
appropriate preventive maintenance, such that the structure, system, or component remained
capable of performing its intended function. Specifically, the licensee failed to monitor
performance of the 96-inch circulating water expansion joint spray shield, a maintenance rule
scoped system, in accordance with their preventive maintenance program and did not
implement (a)(1) goals and corrective actions.
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
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: 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 seals must provide equal or greater fire rating than that of the fire barrier. The
licensee identified a 10 drain line penetrating the fire barrier between the technical support
center and the Unit 1 cable tray room that did not provide the required three hour or greater
fire rating.
Significance/Severity: Green. 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 an adequate
automatic suppression system 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.
Corrective Action References: CR1220302
Minor Violation
No Design Control Measure to Verify Protection against Tornado Differential Pressure
Minor Violation: Title 10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part,
the licensee to have design control measures for verifying or checking the adequacy of
design, such as by the performance of design reviews, using alternate or simplified
calculational methods, or by the performance of a suitable testing program. Contrary to the
above, from at least July 24th, 2023, until January 23, 2024, the licensee did not have a
design control measure in place to verify the EDGs were protected against the effects of the
tornado-generated pressure differential.
Screening: The inspectors determined the performance deficiency was minor because if left
uncorrected, the performance deficiency would not lead to a more significant safety
concern. Specifically, the licensee evaluated the radiator louver design. The design was
similar in construction to industry tornado-rated louvers with a pressure rating of three pounds
per square inch differential (psid). Therefore, the licensee determined that the louver could
withstand a pressure difference up to three psi and the EDG would remain operable. Based
on this evaluation, there was reasonable assurance the EDGs could withstand the differential
pressure effects from a design-basis tornado.
Enforcement: This failure to comply with 10 CFR Part B, Criterion III, Design Control
constitutes a minor violation that is not subject to enforcement 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 January 24, 2024, the inspectors presented the integrated inspection results to David
Wilson, Site Vice President, and other members of the licensee staff.