IR 05000280/2025001
| ML25114A040 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/30/2025 |
| From: | James Baptist NRC/RGN-II/DORS |
| To: | Carr E Dominion Energy |
| References | |
| IR 2025001 | |
| Download: ML25114A040 (1) | |
Text
SUBJECT:
SURRY POWER STATION - INTEGRATED INSPECTION REPORT 05000280/2025001 AND 05000281/2025001
Dear Eric S. Carr:
On March 31, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Surry Power Station. On April 10, 2025, 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.
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.
April 29, 2025 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, James B. Baptist, Chief Projects Branch 4 Division of Operating Reactor Safety 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:
05000280/2025001 and 05000281/2025001
Enterprise Identifier:
I-2025-001-0033
Licensee:
Dominion Energy
Facility:
Surry Power Station
Location:
Surry, VA
Inspection Dates:
January 01, 2025 to March 31, 2025
Inspectors:
S. Battenfield, Operations Engineer
V. Furr, Operations Engineer
D. Jung, Resident Inspector
S. Kennedy, Senior Resident Inspector
Approved By:
James B. Baptist, Chief
Projects Branch 4
Division of Operating Reactor Safety
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
Non-functional Appendix R Fire Door
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000280,05000281/2025001-01
Open/Closed
[P.1] -
Identification
The inspectors identified a Green finding and an associated Non-cited Violation (NCV) of
Technical Specifications (TS) Section 6.4, " Unit Operating Procedures and Programs,"
Section E, associated with the licensee's failure to implement and maintain the facility fire
protection program and implementing procedures, which resulted in a non-functional
Appendix R fire door at the emergency service water pump (ESWP) house.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 and 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
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 an impending winter storm warning on January 6, 2025.
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)
Alternate alternating current diesel following completion of monthly surveillance
testing on January 16, 2025
(2)
Unit 1 turbine driven auxiliary feedwater (TDAFW) pump following completion of
quarterly surveillance testing on February 7, 2025
(3)
Unit 1 charging pump service water system following maintenance on February 20,
2025
(4)
Unit 2 containment spray system following quarterly surveillance testing on March 11,
2025
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 cable vault penetration area, fire zone 1, elevation 15 feet - 0 inches, on
January 8, 2025
(2)
Unit 1 relay room, fire zone 3, elevation 9 feet - 6 inches, on January 8, 2025
(3)
Unit 2 cable vault penetration area, fire zone 2, elevation 15 feet - 0 inches, on
January 8, 2025
(4)
Intake structure emergency service water pump room and intake structure oil tank
room, fire zone 28B and 28C, elevation 18 feet - 0 inches, on February 14, 2025
(5)
Mechanical equipment room #5, fire zone 66, elevation 9 feet - 6 inches, on February
22, 2025
(6)
Fuel oil pump house rooms 1 and 2, fire zones 18A and 18B, elevation 16 feet - 0
inches, on March 6, 2025
(7)
Unit 1 battery room 1A and 1B, fire zones 9 and 10, elevation 9 feet - 6 inches, on
March 11, 2025
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated the onsite fire brigade training and performance during an
unannounced fire drill on March 5, 2025.
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated external flooding mitigation protections in the:
1.
Fuel oil pump house A
2.
Fuel oil pump house B
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
(1)
Biennial Requalification Written Examinations
The inspectors evaluated the quality of the licensed operator biennial requalification
written examination administered on Feb 24-27, 2025.
Annual Requalification Operating Tests
The inspectors evaluated the adequacy of the facility licensees annual requalification
operating test.
Administration of an Annual Requalification Operating Test
The inspectors evaluated the effectiveness of the facility licensee in administering
requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility
licensee is effectively evaluating their licensed operators for mastery of training
objectives.
Requalification Examination Security
The inspectors evaluated the ability of the facility licensee to safeguard examination
material, such that the examination is not compromised.
Remedial Training and Re-examinations
The inspectors evaluated the effectiveness of remedial training conducted by the
licensee, and reviewed the adequacy of re-examinations for licensed operators who
did not pass a required requalification examination.
Operator License Conditions
The inspectors evaluated the licensees program for ensuring that licensed operators
meet the conditions of their licenses.
Control Room Simulator
The inspectors evaluated the adequacy of the facility licensees control room
simulator in modeling the actual plant, and for meeting the requirements contained in
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 implementation of abnormal procedure 1-AP-20.02, Loss of the Unit 1
Plant Computer, and #3 emergency diesel generator (EDG) quarterly performance
testing on January 22, 2025.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1)
The inspectors observed and evaluated NRC requalification validation simulator
activities on January 21, 2025.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 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)
Motor control center (MCC) '2K1' control room chiller '4B' normal feeder breaker
found tripped on December 21, 2024 (CR1279277)
(2)
Potential through wall leakage upstream of 2-SW-544, recirculation spray heat
exchanger 'B' service water flow transmitter '206B' isolation valve, on March 12, 2025
(CR1269884)
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)
Failed bearing for 2-FW-P-3B, Unit 2 'B' motor driven auxiliary feedwater (MDAFW)
pump, failure on November 5, 2024 (CR1275211)
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 emergent risk assessment associated with troubleshooting and repair of Unit 1
TDAFW pump on January 14 and January 15, 2025
(2)
Unit 1 elevated risk due to #1 EDG surveillance and pressurizer block valve stroke
test on January 28, 2025
(3)
Unit 2 elevated risk due to TDAFW pump surveillance failure on February 18, 2025
(4)
Unit 1 elevated risk due to TDAFW pump out of service for planned maintenance on
March 13, 2025
(5)
Risk review regarding Unit 1 main generator standby auto voltage regulator failure on
March 17, 2025
(6)
Unit 1 elevated risk due to #1 EDG surveillance and Unit 1 '1A' component cooling
pump out of service for maintenance on March 24, 2025
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples 1 Partial)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1)
(Partial) CR1280748, common overhead damper connecting Unit 1 and Unit 2
emergency switchgear rooms did not close as expected on January 15, 2025
(2)
CR1280918, Unit 2 B pressurizer pressure control system manual/auto control
station shifted to manual on January 17, 2025
(3)
CR1282232, Unit 2 'D' condenser circulating water inlet valve leaking on February 13,
2025
(4)
CR1282112, Unit 2 service water pump '10A' suction strainer did not isolate offline
basket on February 24, 2025
(5)
CR1282438, Unit 2 'D' condenser circulating water outlet valve leaking grease on
February 27, 2025
(6)
CR1282217, 1-MS-RI-129, auxiliary feedwater (AFW) pump steam exhaust radiation
monitor, periodically spiking to 0.41 millirem/hour on February 3, 2025
(7)
CR1284388, 1-VS-TI-132, main control room chiller E chilled water outlet
temperature indicator, reading below minimum specification on February 28, 2025
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-18-00109, mechanical equipment rooms 3 and 4 charging service water
improvements
(2)
SU-21-00143, Unit 1 main steam trip valve obsolete battery charger replacement
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated Unit 2 refueling outage 2R32 activities from October 27,
2024, to December 6, 2024. The inspectors completed inspection procedure
71111.20, Section 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) (7 Samples)
(1)
0-MPM-0210-01, Control Room Chillers Performance Checks, following control room
chiller troubleshooting and unexpected #2 compressor low oil pressure switch trip on
January 10, 2025 (WO38204325015)
(2)
CAL-046, Source Range Discriminator Voltage and High Voltage Determination,
following investigate and repair of N31, Unit 1 source range nuclear instrument,
erratic indication on January 4, 2025 (WO38204362802)
(3)
1-OPT-FW-003, TDAFW Pump 1-FW-P-2, following replacement of the governor on
the Unit 1 TDAFW pump on January 15, 2025 (WO38204367840)
(4)
0-OPT-SW-001, Emergency Service Water Pump 1-SW-P-1A, following maintenance
package and failure to develop adequate lube oil pressure on January 17, 2025
(5)
0-ECM-0306-02, MCC Maintenance, following low-head safety injection pump 'A'
motor heater breaker maintenance on January 22, 2025 (WO38103466739)
(6)
1-OPT-CT-303, Personnel Airlock Leakage Test (Door seal Test), following
replacement of escape manway seal O-rings on January 30, 2025
(7)
1-OPT-FW-003, TDAFW Pump 1-FW-P-2, following governor valve repair on the Unit
1 TDAFW pump on March 14, 2025 (WO38204369754)
Surveillance Testing (IP Section 03.01) (4 Samples)
(1)
2-OPT-FW-002, MDAFW Pump 2-FW-P-3B, on January 6, 2025
(2)
1-OPT-FW-003, TDAFW Pump 1-FW-P-2, on February 3, 2025
(3)
2-OPT-RS-007, Containment Outside Recirculation Spray Pumps Motor Operated
Valve Stroke Test, on February 27, 2025
(4)
2-OP-FW-002, TDAFW Pump Startup and Shutdown, on March 4, 2025.
Inservice Testing (IST) (IP Section 03.01) (2 Samples)
(1)
0-OPT-EG-005, Number 3 EDG Fuel Oil System Tests, on January 22, 2025
(2)
1-OPT-SI-005, Low-head Safety Injection Pump Test, on February 26, 2025
71114.06 - Drill Evaluation
Required Emergency Preparedness Drill (1 Sample)
(1)
The inspectors observed and evaluated the conduct of an emergency preparedness
drill scenario involving the degradation of three fission product barriers which led to
the declaration of general emergency on March 25, 2025.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)
(1)
Unit 1 (January 1 through December 31, 2024)
(2)
Unit 2 (January 1 through December 31, 2024)
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
(1)
Unit 1 (January 1 through December 31, 2024)
(2)
Unit 2 (January 1 through December 31, 2024)
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
(1)
Unit 1 (January 1 through December 31, 2024)
(2)
Unit 2 (January 1 through December 31, 2024)
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)
(1)
Unit 1 (January 1 through December 31, 2024)
(2)
Unit 2 (January 1 through December 31, 2024)
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
(1)
Unit 1 (January 1 through December 31, 2024)
(2)
Unit 2 (January 1 through December 31, 2024)
INSPECTION RESULTS
Non-functional Appendix R Fire Door
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000280,05000281/2025001-01
[P.1] -
Identification
Open/Closed
The inspectors identified a Green finding and an associated Non-cited Violation (NCV) of
Technical Specifications (TS) Section 6.4, " Unit Operating Procedures and Programs,"
Section E, associated with the licensee's failure to implement and maintain the facility fire
protection program and implementing procedures, which resulted in a non-functional
Appendix R fire door at the emergency service water pump (ESWP) house.
Description: On February 24, 2025, the inspectors performed a walkdown of the ESWP
house, fire zones 28B and 28C, elevation 18 feet. The inspectors identified that the Appendix
R fire door (1-BS-DR-9) separating the two fire zones appeared to have an excessive gap
between the door and the floor. National Fire Protection Association (NFPA) 80, 1970 edition,
Fire Doors and Windows, stated that for swinging doors, the clearance between the door
and the floor shall be not more than three-fourths of an inch. Surry Power Station Technical
Report No. EP-0013, Fire Protection Information Relating to Appendix A to BTP 9.5-1, 1979
FP-SER and National Fire Protection Association (NFPA) Codes listed NFPA 80, 1970
edition, as the licensees standard for Appendix R fire doors.
The licensee measured the gap and confirmed that the clearance exceeded three-fourths of
an inch. As a result, Operations declared door 1-BS-DR-9 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 door be restored to a functional condition within
7 days. The licensee also evaluated if the excessive clearance impacted the functionality of
the carbon dioxide suppression system and determined that the amount of additional leakage
under the door would not have affected functionality. The ESWP house contains the safety-
related diesel driven service water pumps and the associated fuel oil storage tank.
The inspectors concluded that the licensee did not maintain the installation requirements of
NFPA 80 for 1-BS-DR-9. The inspectors determined that the licensee had a reasonable
opportunity to identify the issue. Licensee procedure 0-MPM-1910-11, Inspection (Functional
Check) of NSQ and Special Purpose Doors, was last performed on December 12, 2023. In
addition, plant operators conducted inspections of Appendix R fire doors daily using 0-OSP-
FP-010, Daily Fire Door Inspection. The inspectors noted that the acceptance criteria for
door to floor clearance is listed in 0-MPM-1910-11 but not in 0-OSP-FP-010. The concern
associated with the issue is the potential of fire to spread between zones in the event of a fire.
Corrective Actions: In addition to declaring the fire door non-functional and entering the
associated TRM action statement, the licensee initiated a work order to repair the door. On
February 25, 2025, the licensee repaired the door and exited the TRM action statement.
Corrective Action References: CR1283916
Performance Assessment:
Performance Deficiency: The inspectors found that the licensees failure to maintain the
installation requirements of NFPA 80 for door 1-BS-DR-9, which resulted in non-functional
Appendix R door, was 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, an excessive door to floor clearance affected the
capability of the door to function as a 3-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 October 26, 2023, to inform answers to the
more than minor screening questions and found this condition consistent with more than
minor Example 2.d in that both the licensee and vendor requirements were not met and
would have impacted the fire barriers functionality.
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 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 with
door 1-BS-DR-9 during periodic and daily door inspections.
Enforcement:
Violation: Technical Specification 6.4, Unit Operating Procedures and Programs, Section E,
states, The facility Fire Protection Program and implementing procedures which have been
established for the station shall be implemented and maintained. Surry Power Station
Technical Report No. EP-0013, Fire Protection Information Relating to Appendix A to BTP
9.5-1, 1979 FP-SER and National Fire Protection Association (NFPA) Codes listed NFPA 80,
1970 edition, Fire Doors and Windows, as the requirement for Appendix R fire doors. NFPA
80, Section 5, Installation of Swinging Doors, stated, in part, [t]he clearance between the
door and the floor with either flush or raised sill shall be not more than 3/4 in.
Contrary to the above, prior to February 24, 2025, the licensee did not maintain the facility fire
protection program requirements in accordance with NFPA 80, 1970 edition. Specifically, the
door to floor clearance was more than three-fourths of an inch for door 1-BS-DR-9, ESWP
house to diesel tank room, which resulted in a non-functional Appendix R fire door between
two fire zones.
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 April 10, 2025, the inspectors presented the integrated inspection results to David
Wilson, Site Vice President, and other members of the licensee staff.
On February 26, 2025, the inspectors presented the licensed operator requalification
program inspection results to David Wilson, Site Vice President, and other members of
the licensee staff.