Text

Fire Protection Team Inspection Report 05000280/2025010 and 05000281/2025010
	ML25135A365
Person / Time
Site:	Surry
Issue date:	05/19/2025
From:	Daniel Bacon; NRC/RGN-II/DORS/EB2
To:	Carr E; Virginia Electric & Power Co (VEPCO)
References
	IR 2025010
	Download: ML25135A365 (1)
	v • d • e

SUBJECT:

SURRY POWER STATION - FIRE PROTECTION TEAM INSPECTION REPORT 05000280/2025010 AND 05000281/2025010

Dear Eric S. Carr:

On April 17, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Surry Power Station and discussed the results of this inspection with David Wilson 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.

May 19, 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, Daniel M. Bacon, Chief Engineering Br 2 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:

DPR-32 and DPR-37

Report Numbers:

05000280/2025010 and 05000281/2025010

Enterprise Identifier:

I-2025-010-0045

Licensee:

Virginia Electric & Power Company

Facility:

Surry Power Station

Location:

Surry, VA

Inspection Dates:

March 31, 2025 to April 17, 2025

Inspectors:

W. Monk, Senior Reactor Inspector

J. Montgomery, Senior Reactor Inspector

A. Ruh, Senior Reactor Inspector

Approved By:

Daniel M. Bacon, Chief

Engineering Br 2

Division of Operating Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a fire protection team 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 Implement Administrative Controls When Impairing Halon System Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000280,05000281/2025010-01 Open/Closed None (NPP)71111.21N.

The inspectors identified a Green finding and associated Non-cited Violation (NCV) of Surry license condition 2.I for Unit 1 and 3.I for Unit 2 when the licensee failed to implement administrative controls on the Emergency Switchgear Rooms Halon fire suppression systems while operating emergency ventilation fans.

Additional Tracking Items

None.

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 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

71111.21N.05 - Fire Protection Team Inspection (FPTI) Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)

Main article: IP 71111.21

The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis (FHA) or safe shutdown analysis (SSA).

(1) Halon system in Fire Area 3 (Unit 1 Emergency Switchgear & Relay Rooms ESGR-1)

(2) Sprinkler System in Fire Area 1 (Unit 1 Cable Vault & Tunnel)

(3) Unit 2 Charging System

(4) Unit 2 120VAC Electrical Distribution System

Fire Protection Program Administrative Controls (IP Section 03.02) (1 Sample)

The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis. If applicable, ensure that the licensees FPP contains adequate procedures to implement the selected administrative control. Verify that the selected administrative control meets the requirements of all committed industry standards.

(1) Fire Inspection Program

Fire Protection Program Changes/Modifications (IP Section 03.03) (2 Samples)

The inspectors verified the following:

a. Changes to the approved FPP do not constitute an adverse effect on the ability to safely shutdown.

b. The adequacy of the design modification, if applicable.

c. Assumptions and performance capability stated in the SSA have not been degraded through changes or modifications.

d. The FPP documents, such as the Updated Final Safety Analysis Report, fire protection report, FHA, and SSA were updated consistent with the FPP or design change.

e. Post-fire SSD operating procedures, such as abnormal operating procedures, affected by the modification were updated.

(1) DCP-SU-22-00151 - Unit 1 Interposing Relay Installation in Emergency Bus Normal Supply Breakers

(2) DC-SU-23-00103 - Unit 2 Motor Driven AFW Pump Breaker Appendix R Resolution

INSPECTION RESULTS

Failure to Implement Administrative Controls When Impairing Halon System Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000280,05000281/2025010-01 Open/Closed None (NPP)71111.21N.0 The inspectors identified a Green finding and associated Non-cited Violation (NCV) of Surry license condition 2.I for Unit 1 and 3.I for Unit 2 when the licensee failed to implement administrative controls on the Emergency Switchgear Rooms Halon fire suppression systems while operating emergency ventilation fans.

Description:

The Unit 1 and 2 Emergency Switchgear (ESGR) and Relay Rooms credit fire suppression via a Halon 1301 fire suppression system. These systems are total-flooding systems and are manually actuated.

The Halon suppression system in the Unit 1 and 2 ESGRs partially relied on safety-related ventilation dampers, 1-VS-MOD-104B and 2-VS-MOD-204B respectively, to be in a closed position to ensure an adequate Halon concentration could be achieved to suppress a fire.

These motor operated dampers were normally closed except when emergency ventilation fans 1-VS-F-42 or 2-VS-F-42 were in operation. Inspectors identified that the station operated these emergency ventilation fans on an infrequent basis throughout the year during required surveillance testing and also as a Technical Specification (TS) 3.21.C.1 mitigating action for maintenance activities that created breaches in the ESGR pressure boundary. The basis for this mitigating action was to supply fresh, filtered air from the turbine building into the ESGR to lessen the effect on ESGR occupants from potential hazards of a radiological or chemical event, or a challenge from smoke. Although operating these fans was appropriate for those circumstances, the site did not recognize that the continuous supply of 1000 cubic feet per minute of fresh air into the ESGR could impair the Halon fire suppression system by diluting the Halon concentration in the local vicinity of the supply duct discharge.

The normal operating procedure for the emergency ventilation system, 0-OP-VS-014 Main Control Room Emergency Ventilation System, had precautions and limitations to not place the system in service during a fire; however, if the system was already in operation, there was no direction or guidance to ensure the fans were off and the associated motor-operated dampers were closed prior to manually discharging Halon in the ESGR. The licensees procedures also did not address Halon system functionality when the emergency ventilation fans were in operation.

The licensees Technical Requirements Manual (TRM) 3.7.5 required the Halon system for the ESGR to be functional whenever equipment in the Halon protected area is required to be operable. When this system is nonfunctional, a fire watch with backup fire suppression equipment for the ESGR was to be established within one hour and the system restored to functional status within 14 days. The licensees administrative procedure CM-AA-FPA-100, Fire Protection/Appendix R (Fire Safe Shutdown) Program, section 3.1.2.j stated that Whenever fire protection systems, portion of a system, or equipment are impaired or reduced in status for any reason the Shift Manager shall be notified immediately. The Shift Manager shall[e]nsure that appropriate actions are taken to provide additional protection (as defined in the TRM). When inspectors reviewed operational logs and the past 12 months of operational history of these fans, it showed approximately 114 to 134 hours0.00155 days <br />0.0372 hours <br />2.215608e-4 weeks <br />5.0987e-5 months <br /> of operation for each fan, but there were no associated Halon system impairments or TRM protective actions taken while the fans were in operation.

Corrective Actions: As an interim action, the operations department created a night order that gave guidance to establish an hourly fire watch upon placing 1-VS-F-42 or 2-VS-F-42 in service. The licensee also planned to evaluate procedural guidance for operating the emergency ventilation system.

Corrective Action References: 1288172

Performance Assessment:

Performance Deficiency: The failure to ensure appropriate actions were taken, per section 3.1.2.j of CM-AA-FPA-100, when the ESGR Halon fire protection system was impaired, was a performance deficiency. Specifically, while emergency ventilation was in service, additional protection in the ESGR was not provided.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the halon system could be potentially nonfunctional during the time the emergency ventilation system is operated, and operation of this system is allowed by TS for up to 90 days.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. Using Step 1.3, inspectors determined that this finding had a low degradation because of the limited amount of time that the plant has been, and would be, in the vulnerable configuration.

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Surry license condition 2.I for Unit 1 and 3.I for Unit 2 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. Section 9.10 of the UFSAR describes the Fire Protection Program and Section 9.10.1 states, in part, that compliance with regulatory requirements is contained in, among other documents, the Fire Protection Program document and associated Administrative Procedures. Administrative Procedure CM-AA-FPA-100, Fire Protection/Appendix R (Fire Safe Shutdown) Program, Section 3.1.2.j states, in part, "Whenever fire protection systems, portion of a system, or equipment are impaired or reduced in status for any reason the Shift Manager shall be notified immediately. The Shift Manager shall[e]nsure that appropriate actions are taken to provide additional protection (as defined in the Technical Requirements Manual)."

Contrary to the above, since at least 2008, the licensee failed to ensure appropriate actions were taken to provide additional protection in the ESGR while emergency ventilation was in service.

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 17, 2025, the inspectors presented the fire protection team inspection results to David Wilson and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

v t e Inspection Report - Surry - 2025010
80 \| 81 \| 82 \| 83 \| 84 \| 85 \| 86 \| 87 \| 88 \| 89 \| 90 \| 91 \| 92 \| 93 \| 94 \| 95 \| 96 \| 97 \| 98 \| 99 00 \| 01 \| 02 \| 03 \| 04 \| 05 \| 06 \| 07 \| 08 \| 09 \| 10 \| 11 \| 12 \| 13 \| 14 \| 15 \| 16 \| 17 \| 18 \| 19 \| 20 \| 21 \| 22 \| 23 \| 24 \| 25 \|
2025 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 10(0) Security 401(0) 402(0) 403(0) Operator Exams Emergency Planning Other

IR 05000280/2025010