IR 05000280/2024002

Integrated Inspection Report 05000280/2024002 and 05000281/2024002

ML24213A093
Person / Time
Site:	Surry
Issue date:	08/01/2024
From:	Matthew Fannon Division Reactor Projects II
To:	Carr E Virginia Electric & Power Co (VEPCO)
References
IR 2024002
Download: ML24213A093 (17)

Text

SUBJECT:

SURRY POWER STATION - INTEGRATED INSPECTION REPORT 05000280/2024002 AND 05000281/2024002

Dear Eric S. Carr:

On June 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Surry Power Station. On July 15, 2024, the NRC inspectors discussed the results of this inspection with James Shell, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

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

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Surry Power Station.

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 1, 2024

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: DPR-32 and DPR-37

Report Numbers: 05000280/2024002 and 05000281/2024002

Licensee: Virginia Electric and Power Company

Facility: Surry Power Station

Location: Surry, VA

Inspection Dates: April 01, 2024 to June 30, 2024

Inspectors: J. Bell, Senior Health Physicist J. Diaz-Velez, Senior Health Physicist S. Downey, Senior Reactor Inspector N. Eckhoff, Health Physicist D. Jung, Resident Inspector S. Kennedy, Senior Resident Inspector D. Neal, Health Physicist J. Rivera, Health Physicist

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

Enclosure

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.

List of Findings and Violations

Failure to Maintain Adequate Procedure to Ensure Plant Stability Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.3] - Change 71153 NCV 05000280/2024002-01 Management Open/Closed A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specification 6.4.A.7, Unit Operating Procedures and Programs, was identified when the licensee failed to provide detailed written procedures with appropriate instructions to perform a maintenance activity during a Unit 1 refueling outage, which had an effect on plant stability during power ascension following reactor startup and was a contributing cause to a reactor trip.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 began the inspection period at rated thermal power. On April 7, 2024, the unit was shut down for a planned refueling outage. The unit was placed online on June 2. At approximately 13 percent power, the unit experienced a reactor trip as a result of a turbine trip. Following correction of the cause of the turbine trip, the unit was returned to rated thermal power on June 8, and remained at or near rated thermal power for the remainder of the 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 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.

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 emergency switchgear rooms on June 27, 2024.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 1 residual heat removal (RHR) system walkdown during reactor coolant system (RCS) cooldown, prior to RHR system being placed in service on April 7, 2024

(2) Unit 1 RCS level instrumentation during lowered inventory condition on April 11, 2024

(3) Offsite power during 1H 480 volts alternating current (VAC) safety bus outage on April 23, 2024

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) Spent fuel pool pit cooling system walkdown during Unit 1 full core offload on April 20, 2024

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (7 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) Unit 1 reactor containment, fire zone 15, elevation 47 feet - 4 inches; elevation 18 feet - 4 inches; elevation 27 feet - 7 inches; elevation (-) 3 feet - 6 inches, on April 9, 2024

(2) Mechanical equipment room #3, fire zone 45, elevation 9 feet - 6 inches, on April 24, 2024

(3) Unit 2 safeguards valve pit, fire zone 20, elevation 28 feet - 6 inches, 19 feet - 6 inches, on April 28, 2024

(4) Unit 2 switchgear room, fire zone 13, elevation 58 feet - 6 inches, on May 5, 2024

(5) Turbine building, fire zone 43, elevation 45 feet - 3 inches, on May 7, 2024

(6) Fuel oil pump houses 'A' and 'B', fire zones 18A and 18B, elevation 16 feet, on May 17, 2024

(7) Electrical equipment room - low level, fire zone 28A, elevation 13 feet, on May 23, 2024

===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 on Unit 1 during refueling outage S1R32 from April 15 to April 18, 2024.

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) 1. Liquid Penetrant Examination a. Weld 1-44A, pipe to valve weld, American Society of Mechanical Engineers (ASME) Class 2. This included a review of the associated welding activities.

2. Magnetic Particle Examination a. Weld 2-29, valve to elbow weld, ASME Class 2 b. Weld 4-29, valve to elbow weld, ASME Class 2 3. Radiographic Examination a. Weld 1-44A, pipe to valve weld, ASME Class 2. This included a review of the associated welding activities.

4. Ultrasonic Examination a. Weld 1-08, elbow to pipe weld, ASME Class 1 b. Weld 1-11, elbow to pipe weld, ASME Class 1 c.

Weld 1-48, pipe to elbow weld, ASME Class 2. This included a review of the associated welding activities.

d. Weld 2-29, valve to elbow weld, ASME Class 2 e. Weld 4-29, valve to elbow weld, ASME Class 2

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:

(1) 1. Boric acid walkdown - April 16, 2024 2. Review of the following boric acid evaluations (by condition report [CR]

number):

a. CR1247872 3. Review of the following corrective actions performed for evidence of boric acid leaks that were identified (by condition report number):

a. CR1192835 b. CR1211570 c.

CR1215871 d. CR1215872 e. CR1216069 f.

CR1234231 g. CR1234970

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 observed and evaluated licensed operator performance in the control room during Unit 1 shutdown in preparation for the refueling outage on April 6 and 7, 2024.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the classroom and simulator during just-in-time training in preparation for Unit 1 startup following the refueling outage on May 2, 2024.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (3 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 2 A boric acid transfer pump on March 1, 2024 (CR1252218)

(2) 1-MS-SV-101B, steam generator B safety valve, failed as-found lift set point on April 19, 2024 (CR1257089)

(3) Unit 1 pressurizer level transmitter on May 13, 2024 (SU-23-00129). Operating Experience Smart Sample 2019-01, Commercial Grade Dedication, Procurement, and Design Control was used to inform this sample.

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) Unsatisfactory receipt inspection of Unit 1 reactor vessel head O-ring on April 4, 2024 (CR1255541)

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (6 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 shutdown risk plan in preparation for 1R32 refueling outage on April 7, 2024

(2) Unit 1 elevated shutdown risk due to NI-31 and NI-32, source range nuclear instruments, out of service on April 7, 2024

(3) Unit 1 elevated shutdown risk and Unit 2 elevated online risk during 1H 480 VAC dead bus outage and #1 emergency diesel generator (EDG) out of service on April 23, 2024

(4) Unit 2 elevated risk due to C reserve station service transformer out of service for maintenance on May 2, 2024

(5) Unit 2 high risk plan associated with investigation of pinhole leak on component cooling heat exchangers service water supply piping on May 5, 2024

(6) Unit 2 elevated risk due to 1-SW-S-2A, charging pump service water pump suction strainer, maintenance on May 21, 2024

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (9 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) CR1255406, Emergency service water pump (ESWP) house front access missile door (1-STR-RSD-14) will not close, on April 3, 2024

(2) CR1255708, Unit 2 scaler timer drawer SQC 277 needs calibration on April 7, 2024

(3) CR1255768, 1-RM-RI-159/160, containment particulate and gas monitors, skid high flow with containment hatches open, on April 8, 2024

(4) CR1256396, 1-CH-P-1A, Unit 1 A charging pump, junction box failure on April 12, 2024

(5) CR1256729, Rebar corrosion identified in the ESWP house on April 16, 2024

(6) CR1257093, 1-MS-176, 178, and 182, Unit 1 auxiliary feedwater pump main steam supply header check valves, failed as-found inspections on April 19, 2024

(7) CR1257674, Environment temperature of Unit 1 loop 'A' hot leg narrow range temperature detector found to be higher than the equipment is qualified, on April 25, 2024

(8) CR1258554, Through-wall leakage on a two-inch pipe branch line off the service water header, which supplies service water to the component cooling heat exchangers, on May 5, 2024

(9) CR1244698, Engine oil leak on 1-SW-P-1C, ESWP C on May 14, 2024

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) SU-22-00166, Temporary Modification - Computer Enhanced Rod Position Indication System Shutdown Bank B J07 Rod Position Indication Detector Secondary Winding Resistance Signal Modification

(2) SU-23-00128, Unit 1 Replacement Thermal Shield Flexures

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Partial)

(1) (Partial)

The inspectors evaluated Unit 1 refueling outage 1R32 activities from April 7, 2024, to June 8, 2024. The inspectors completed inspection procedure 71111.20, except Sections 03.01(c)(11)(d) and 03.01(e).

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) (8 Samples)

(1) 1-PT-1.1, Nuclear Instrumentation System Trip Channel Test Prior to Start-Up, following N32, Unit 1 source range detector, replacement on April 9, 2024 (work order

[WO]38204344068)

(2) CAL-048, Nuclear Instrumentation Intermediate Range Drawer, following N36, Unit 1 nuclear instrumentation intermediate range high voltage power supply replacement on April 7, 2024 (WO38204306766)

(3) 0-ECM-1406-05, Auxiliary Feedwater Pump (AFW) (Allis-Chalmers) Motor Maintenance, following 1-FW-P-3B, motor driven AFW pump, maintenance package on April 12, 2024 (WO38204309579)

(4) 1-OPT-EG-006, EDG 1 Compressor Discharge Check Valve Leak Test, following #1 EDG compressor discharge check valve replacement on April 18, 2024 (WO38204178202)

(5) 1-EPT-1804-26, Perform As-Found or After Adjustment Agastat Time Delay Relay Test, following outside recirculation spray pump '2A' Agastat time delay relay replacement on April 22, 2024 (WO38204345232)

(6) 0-OPT-SW-007 OTO 1, Emergency Service Water Pump 1-SW-P-1A Comprehensive Test, following A ESWP pedestal replacement project on May 23, 2024 (SU-15-

===01083)

(7) 0-ECM-1404-04, 480V Motor Load Check After Mechanical Maintenance, and 0-NSP-VS-006, Air Handler Airflow Measurement, following Unit 1 emergency switchgear air handling unit motor replacement on May 11, 2024 (WO38204346422)

(8) 1-MOP-FW-002, Removal from and Return to Service of Turbine Driven AFW Pump 1-FW-P-2, after repacking the turbine driven AFW pump on June 6, 2024 (WO38204354811)

Surveillance Testing (IP Section 03.01)===

(1) 1-OPT-SI-013, Valve Inservice Testing - Leak Test of Low Head Safety Injection Pump Recirc Valves, on April 7, 2024

(2) 1-OPT-ZZ-001, Engineered Safety Features Actuation with Undervoltage and Degraded Voltage - 1H Bus, on April 9, 2024

(3) 2-PT-18.8, Charging Pump Service Water Performance, on May 25, 2024

(4) 1-OPT-FW-003, Turbine Driven Auxiliary Feedwater Pump, 1-FW-P-2, Operations Periodic Test, on June 1, 2024

Inservice Testing (IST) (IP Section 03.01) (1 Sample)

(1) 1-PT-41.2, Cold Shut Down Test of Component Cooling Check Valves and Trip Valves for RHR Heat Exchangers and Reactor Coolant Pumps, performed on 1-CC-TV-140B, reactor coolant pump thermal barrier component cooling water return line outside containment trip valve on April 29, 2024

Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)

(1) 1-OPT-CT-201, Containment Isolation Valve Local Leak Rate Testing (Type C Containment Testing), on June 18, 2024

Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) 2-OP-RC-014, Identifying Increased RCS Leakage, on June 25, 2024

71114.06 - Drill Evaluation

Additional Drill and/or Training Evolution (1 Sample)

The inspectors evaluated:

(1) The inspectors observed and evaluated the conduct of an emergency preparedness drill scenario involving a steam generator tube rupture and opening of a steam generator safety relief valve on June 25,

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) (2 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) Egress of personnel and material at the radiologically controlled area access point, along with technician response to personal contamination alarms

(2) Radiation protection staff count survey material in low background areas to ensure accuracy of survey results

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) RWP 2516, Lower internals lift and set activities

(2) RWP 2506, Alpha level III, valve maintenance and equipment in alpha level III areas

(3) RWP 2133, Safety injection check valve maintenance

(4) RWP 1532, Unit 1 entries into loops and motor cubes

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)

The inspectors evaluated licensee controls of the following high radiation areas (HRAs) and very high radiation areas (VHRAs):

(1) Very high radiation areas in containment during lower internals lift and set

(2) Locked high radiation area controls in the RHR flats

(3) Locked high radiation area of the Unit 1 volume control tank room

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.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (1 Sample)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) Units 1 and 2 main control room air filtration systems

Temporary Ventilation Systems (IP Section 03.02) (1 Sample)

The inspectors evaluated the configuration of the following temporary ventilation systems:

(1) High efficiency particulate filter (HEPA) unit (HV-500-16), tested on February 2, 2024

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.

Internal Dosimetry (IP Section 03.03) (1 Sample)

The inspectors evaluated the following internal dose assessments:

(1) Positive whole-body count on November 2, 2022

Special Dosimetric Situations (IP Section 03.04) (2 Samples)

The inspectors evaluated the following special dosimetric situations:

(1) Declared pregnant worker on January 31, 2023

(2) Multibadge dosimetry pack ID #23-3502-13

71124.05 - Radiation Monitoring Instrumentation

Walkdowns and Observations (IP Section 03.01) (10 Samples)

The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:

(1) FASTCAN whole body counter, whole body count room, administration building.

Observed daily quality control tests performed on the stand-up and chair detectors.

(2) Telepoles SN# 6607-007, 6607-012, 6607-004, 6607-106, 6607-121, and 427021-152

(3) Thermo Scientific Radeye GX, SN# 0689, 11038, 11081, 10871, 0528, 11370, 0533,

===11034, and 10869

(4) Eberline AMS-4, SN #801, 797, and 627

(5) Canberra Argos-5PAB Zeus, SN: 1112-250, 1112-249, and 1112-248. Observed surveillance test.

(6) Canberra GEM5, SN: 1604-050, and 1604-049. Observed surveillance test.

(7) Canberra Cronos 4, SN: 1303-067, and Cronos 11, SN: 1203-068. Observed surveillance test.

(8) 1-GW-RM-130, plant vent radiation monitor

(9) 1-VG-RM-131, plant vent #2 radiation monitor

(10) 1-RRM-RITS-131, liquid radwaste radiation monitor

Calibration and Testing Program (IP Section 03.02)===

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1) 1-IPT-CC-RM-RMS-127, containment high range radiation monitor, calibrated on March 25, 2021

(2) 1-IPT-CC-RM-RMS-127, containment high range radiation monitor, calibrated on September 6, 2022

(3) 1-IPT-CC-RM-RMS-128, containment high range radiation monitor, calibrated on September 7, 2022

(4) 1-IPT-CC-RM-RMS-128, containment high range radiation monitor, calibrated on March 23, 2021

(5) Eberline AMS 4, SN #627, calibrated on September 5, 2023

(6) Eberline AMS 4, SN #797, calibrated on September 5, 2023 and September 8, 2023

(7) Eberline AMS 4, SN #801, calibrated on September 5, 2023

(8) Sirius-5PAB Hand and Foot Monitor, SN #1112-256, calibrated on February 6, 2024

(9) Sirius-5PAB Hand and Foot Monitor, SN #1712-179, calibrated on April 12, 2024

(10) Thermo Scientific Radeye GX, SN #0689 calibrated on April 2, 2024

(11) Thermo Scientific Radeye GX, SN #10879 calibrated on October 26, 2023

(12) FASTCAN whole body counter, calibrated on July 27 and August 10, 2023

(13) Canberra Genie/Apex HP-Ge, detector #2, calibrated on October 20, 2023 (multiple geometries)

(14) MGP Telepole, SN #6607-007, calibrated on February 1, 2024

Effluent Monitoring Calibration and Testing Program Sample (IP Section 03.03) (3 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1) 1-GW-RM130, plant vent radiation monitor (A, B, and C Channels), calibrated on June 30, 2022 and April 1, 2024

(2) 1-VG-RM-131, plant vent #2 radiation monitor (A, B, and C Channels), calibrated on November 1, 2023 and April 7, 2024

(3) 1-RRM-RITS-131, liquid radwaste radiation monitor, calibrated April 28, 2022 and November 30,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===

(1) Unit 1 (July 1, 2023, through June 30, 2024)

(2) Unit 2 (July 1, 2023, through June 30, 2024)

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) February 9, 2023, through March 31 2024

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) May 1, 2023, through March 31, 2024

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Operations to determine protected equipment process alignment and differences among the fleet (CR1228106, CA11850658, CA11850629)

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.

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Follow up (IP Section 03.01)

(1) The inspectors evaluated the licensee's response to a Unit 1 reactor trip caused by a turbine trip at approximately 13 percent rated thermal power on June 2,

INSPECTION RESULTS

Failure to Maintain Adequate Procedure to Ensure Plant Stability Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.3] - Change 71153 NCV 05000280/2024002-01 Management Open/Closed A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specification 6.4.A.7, Unit Operating Procedures and Programs, was identified when the licensee failed to provide detailed written procedures with appropriate instructions to perform a maintenance activity during a Unit 1 refueling outage, which had an effect on plant stability during power ascension following reactor startup and was a contributing cause to a reactor trip.

Description:

On June 2, 2024, at 1708, Surry Unit 1 experienced an uncomplicated automatic reactor tripped due to a turbine trip at approximately 13 percent reactor power, during power ascension following a refueling outage. The turbine tripped while the operators were attempting to reset the turbine control system after identifying that the turbine control system did not transition from speed control mode to load control mode following synchronization to the electrical grid.

Operators placed the unit online at 1428 on June 2, 2024, and noted that turbine load was slowly increasing, the turbine control system was in the speed control mode, and the main generator output breaker cycling test mode was enabled. Normally, the turbine control system transitions automatically to the load control mode following synchronization. However, with the breaker cycling test mode enabled, the turbine control system could not automatically transition to speed control mode.

The licensee performed a post-trip review to determine the cause of the turbine trip/reactor trip. They determined that with the main generator breaker cycling test mode enabled at power, operators were unable to change turbine load. The licensee performed troubleshooting to disenable the test mode. However, the licensee was unaware that the turbine trip logic was partially made up, and the troubleshooting efforts to reset the turbine control system resulted in completing the logic for a turbine trip. This led to a turbine trip and subsequent reactor trip.

The licensee determined that a procedure used to support a maintenance activity during Unit 1 refueling outage was inadequately revised, which left the main generator breaker cycling test mode enabled. Specifically, on March 6, 2023, the licensee revised procedure 1-ECM-2402-03, Main and Station Service Transformer Backfeed Setup and Removal, which added a step to Activate Breaker Cycling Test. However, the revision did not include a step to disenable the test mode. This procedure was performed on May 1, 2024, in support of procedure 1-ECM-2403-03, RSS Transformer C Outage with Backfeed of Transfer Bus F.

Also, the licensee determined that procedure 1-OP-TM-001, Turbine - Generator Startup to 20% - 25% Turbine Power, did not have steps for operators to ensure that the breaker cycling test mode is in the appropriate mode prior to turbine-generator startup and synchronization to the electrical grid.

The inspectors reviewed the licensees post-trip review report and associated documents and determined that the licensee did not adequately implement the requirements of Technical Specification, Section 6.4, Unit Operating Procedures and Programs. Subsection A.7 requires that detailed written procedure with appropriate check-off lists and instructions shall be provided for preventive or corrective maintenance operations which would have an effect on the safety of the reactor. Specifically, 1-ECM-2402-03 did not include a step to disenable the breaker cycling test mode, which resulted in leaving the turbine control system in an undesirable state following completion of the maintenance activity, and subsequently, was a contributing cause of a reactor trip.

Corrective Actions: The licensee completed immediate corrective actions to restore the plant configuration to the expected state and revised affected procedures to remove deficiencies and vulnerabilities for future operation. Also, the licensee initiated a corrective action assignment to perform a root cause analysis of the event, intended to include a determination of the root cause of the event and any additional contributing causes.

Corrective Action References: CR1260948

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensees failure to provide a procedure with appropriate instructions that had an effect on the safety of the reactor was a performance deficiency that was reasonably within licensees ability to foresee and correct.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the performance of the deficient procedure contributed to a reactor trip. The inspectors used IMC 0612, Appendix E, Examples of Minor Issues, dated November 1, 2023, to inform answers to the more than minor screening questions and found this condition consistent with more than minor example 4.b.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 1, Initiating Events Screening Questions, Section B, Transient Initiators, the inspectors determined the finding was of very low safety significance (Green), because the finding did not result in a reactor trip AND the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.

Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.

Specifically, the licensee failed to use a systematic process to evaluate and implement a change to procedure 1-ECM-2402-03, allowing the breaker cycling test mode to remain enabled, which resulted in leaving the turbine control system in an undesirable state following completion of the maintenance activity and subsequently, was a contributing cause of a reactor trip.

Enforcement:

Violation: Technical Specification 6.4.A.7, Unit Operating Procedures and Programs, requires, in part, Detailed written procedures with appropriate check-off lists and instructions shall be provided for the following conditions[p]reventive or corrective maintenance operations which would have an effect on the safety of the reactor.

Contrary to the above, the licensee failed to provide detailed written procedures with appropriate instructions to perform a maintenance activity during a Unit 1 refueling outage, which had an effect on the safety of the reactor during power ascension following reactor startup. Specifically, on March 6, 2023, the licensee revised procedure 1-ECM-2402-03, Main and Station Service Transformer Backfeed Setup and Removal, which added a step to Activate Breaker Cycling Test. However, the revision did not include a step to disenable the test mode. This procedure was performed on May 1, 2024, in support of C reserve station transformer maintenance. As a result, the licensee's performance of 1-ECM-2402-03 left the turbine control system in an undesirable state, which was a contributing cause to a reactor trip on June 2, 2024.

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 15, 2024, the inspectors presented the integrated inspection results to James Shell, Plant Manager, and other members of the licensee staff.

• On April 18, 2024, the inspectors presented the inservice inspection results to James Shell, Plant Manager, and other members of the licensee staff.

• On May 14, 2024, the inspectors presented the radiation protection inspection results to James Shell, Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.08P Corrective Action Condition Reports 1215871, 1215872, 1216069, 1234231, 1234970, 1247872,

Documents (by Number) 1256394

Corrective Action CRs (by Number) CR1256776, CR1256781, CR1256784

Documents

Resulting from

Inspection

Engineering ETE-CEP-2024-Surry Unit 1 Steam Generator Integrity Review Assessment 03/22/2024

Evaluations 1002 (R32)

NDE Reports ISI-1-MT-24-002 Magnetic Particle Examination of 11448-WMKS-0103A2- 04/12/2024

2/30-SHP-2/4-29

ISI-1-MT-24-003 Magnetic Particle Examination of 11448-WMKS-0103A2- 04/12/2024

1/30-SHP-1/2-29

ISI-1-UT-24-011 Ultrasonic Examination of 11448-WMKS-0103A2-2/30-SHP- 04/12/2024

2/4-29

ISI-1-UT-24-012 Ultrasonic Examination of 11448-WMKS-0103A2-1/30-SHP- 04/12/2024

1/2-29

ISI-1-UT-24-031 Ultrasonic Examination of 11448-WMKS-0122L1/12-SI-45/1- 04/18/2024

ISI-1-UT-24-032 Ultrasonic Examination of 11448-WMKS-0122L1/12-RC- 04/18/2024

2/1-08

Work Orders Work Orders (by 38204291162

Number)

71124.03 Corrective Action CR1259049 Procedure enhancements for Fleet Procedure RP-AA-163, 05/09/2024

Documents Inspection and Inventory of Respiratory Protection

Resulting from Equipment

Inspection

Procedures RP-AA-163 Inspection and Inventory of Respiratory Protection Rev. 8

Equipment

71124.05 Corrective Action CR #1259036 NRC Identified Procedure Error (Procedure 1-IPT-CC-GW- 05/09/2024

Documents RM-130)

Resulting from

Inspection

Inspection Type Designation Description or Title Revision or

Procedure Date

Work Orders WO Calibrate Rad Monitor with updated source calculations 05/10/2024

1. 38204350970

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