IR 05000280/2020002

Integrated Inspection Report 05000280/2020002 and 05000281/2020002 and Exercise of Enforcement Discretion

ML20223A227
Person / Time
Site:	Surry
Issue date:	08/10/2020
From:	Stewart Bailey NRC/RGN-II/DRP/RPB4
To:	Stoddard D Virginia Electric & Power Co (VEPCO)
References
EA-20-096 IR 2020002
Download: ML20223A227 (24)

Text

August 10, 2020

SUBJECT:

SURRY POWER STATION - U.S. NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 05000280/2020002 AND 05000281/2020002 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Stoddard:

On June 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Surry Power Station. On July 16, 2020, the NRC inspectors discussed the results of this inspection with Mr. Doug Lawrence, 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.

A finding and an associated violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, was identified. Because this finding and violation was identified during the discretion period covered by Enforcement Guidance Memorandum 15-002, Rev. 1, Enforcement Discretion for Tornado Missile Protection Non-compliance, and because the licensee was implementing compensatory measures, the NRC is exercising enforcement discretion by not issuing an enforcement action and is allowing continued reactor operation.

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.

Sincerely,

/RA/

Stewart N. Bailey, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 05000280 and 05000281 License Nos. DPR-32 and DPR-37 Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

ML20223A227 OFFICE RII: DRP/PB4 RII: DRP/PB4 RII: DRP/PB6 RII: EICS RII: DRP/PB4 RII: DRP/PB4 NAME L. McKown C. Read A. Rosebrook M. Kowal D. Jackson S. Bailey DATE 8/7/2020 8/7/2020 8/6/2020 8/7/2020 8/6/2020 8/10/2020

U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT Docket Numbers: 05000280 and 05000281 License Numbers: DPR-32 and DPR-37 Report Numbers: 05000280/2020002 and 05000281/2020002 Enterprise Identifier: I-2020-002-0067 Licensee: Virginia Electric and Power Company Facility: Surry Power Station Location: Surry, VA Inspection Dates: April 01, 2020 to June 30, 2020 Inspectors: L. McKown, Senior Resident Inspector M. Read, Resident Inspector A. Butcavage, Reactor Inspector C. Fontana, Emergency Preparedness Inspector B. Kellner, Senior Health Physicist W. Pursley, Health Physicist S. Sanchez, Senior Emergency Preparedness Insp J. Walker, Emergency Response Inspector Approved By: Stewart N. Bailey, 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

Lift of Surry Unit 2 B Pressurizer Safety Relief Valve while Partially Installed in System Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71152 Systems NCV 05000281/2020002-01 Complacency Open/Closed A self-revealing Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V,

Instructions, Procedures, and Drawings, was observed associated with the licensees inability to accomplish an activity affecting quality, the lifting and rigging of the Unit 2 B pressurizer safety relief valve, in accordance with licensee documented instructions and procedures, 0-MCM-0424-02, Pressurizer Safety Valve Installation, and GMP-001, Heavy Load Rigging and Movement. This resulted in damage to the valve and adverse impact on the decay heat removal key safety function while in cold shutdown from May 25, through May 29, 2020.

Additional Tracking Items

Type Issue Number Title Report Status Section LER 05000280,05000281/ Items Non-Conforming to Design 71153 Closed 2019-002-00 for Tornado Missile Protection EDG EA-20-096 Items Non-Conforming to Design 71153 Open/Closed for Tornado Missile Protection

REPORT DETAILS

PLANT STATUS Unit 1 operated at or near rated thermal power (RTP) for the entire inspection period.

Unit 2 began the inspection period at RTP. On April 7, 2020, Unit 2 began coast down from RTP to 80 percent RTP. On May 3, 2020, the licensee performed a shutdown for entry into a scheduled refueling outage. On June 2, 2020, Unit 2 achieved criticality following the refueling outage returned to RTP on June 6,

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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin teleworking and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

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 hurricane season and seasonal high temperatures for the following systems:

• AC Distribution

• Emergency Service Water

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

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

(1) Unit 2 service water to recirculation spray heat exchangers, on April 6, 2020 (2) #1 and #3 emergency diesel generators prior to a high-risk lift near the 'C' reserve station service transformer cables, on April 16, 2020

(3) 1H and 2J emergency switchgear prior to excavations near the 'C' reserve station service transformer underground cables, on April 23, 2020

(4) Electric and diesel driven fire pumps, fire protection tanks, and associated piping upstream of the fire protection loop, following pipe rupture and restoration, on

May 12, 2020 Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) Unit 2 residual heat removal system, on May 6, 2020

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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 and 2 turbine building basements, on May 1, 2020

(2) Unit 2 containment, on May 6, 2020

(3) Fire pump house, on May 12, 2020

(4) Unit 2 volume control tank room, on May 20, 2020

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Unit 1 safeguards building, on June 11, 2020

Cable Degradation (IP Section 03.02) (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) Cable vaults 1-EP-MH-1, 1-EP-MH-2, 1-EP-MH-3 associated with WO 38204198767, on June 18, 2020

71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)

(1) During the current COVID-19 posture, the inspectors completed this inspection by remote methods which included program owner interviews, reviews of sample licensee inspection procedures and review of available samples of non-destructive examination inspection results. These reviews support a conclusion IAW the IP objective to determine that the license ASME Section XI and Augmented Programs provide reasonable assurance that the reactor coolant system boundary, steam generator tubes, reactor vessel internals and risk-significant piping system boundaries are appropriately monitored for degradation; and that repairs and replacements were appropriately fabricated, examined and accepted based on the following activities from 5/4/20 to 5/13/20.

03.01.a - Documentation Reviewed for Nondestructive Examination and Welding Activities.

• Ultrasonic Examination (UT), Pressurizer Spray Piping Component ID,11548-WMKS-0125A1 / 4-RC-314 / 1-10, Pipe Bend to Pipe, ASME Class 1

• UT of Component ID,11548-WMKS-0125A1 / 4-RC-314 / 1-07, Pipe to Bent Pipe, ASME Class 1

• Magnetic Particle Examination (MT), PZR Support Skirt Integral Attachment Weld ASME Class 1

• VT-2 Leakage Check, Comp ID 11548-WMKS-RC-R-1.1, Penetration Nozzles, Class 1

• Welds, Work Order 38103681988, Valve 02-CH--297 Replacement, ASME Class 2 03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Related Activities.

• Reviewed and discussed with program owner, ER-AA-NDE-VT-604, Visual Examination (VE) for Leakage of PWR Reactor Head Penetrations Procedure for current N-729-4 Code Case Edition and plans for revision due to emergent N-729-6 revisions.

• Reviewed and discussed Surry Response to Operating Experience contained in Westinghouse NSA-18-1 and NSA-20-1, concerning control rod drive mechanism thermal sleeve degradation.

03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities.

• 2-RH-22, RHR-Hx-1B Drain, ASME Cl. 2, Evaluation CR-1108834, CR-1067618, WO-8103814031

• 2-CS-PI-233B, Cl. 2, Refueling Water Recirc. Pump 2B, Suction PSI Indicator, WO-38204195276

• 2CH-, FCV-2122, Charging Flow-Control Valve, Cl 2, CR-1071834, WO-38103669059 03.01.d - Pressurized-Water Reactor Steam Generator Tube Examination Review Activities.

• Existing Tech Spec Section 6.0.Q, Steam Generator Program, Amendment No. 278

• Surry Unit-2 Tech Spec Amendment No. 299

• Review of 2018 Condition Monitoring an Operational Assessment

• Verified Operations Surveillance procedure 0-OSP-RC-002, Steam Generator Primary to Secondary Leakage Monitoring, has been updated for SG-B leak criteria required by TS Amendment No. 299 Additional Reactor Internals Operating Experience Review Activities

• Reviewed and Discussed Surry response to TB-19-5, Thermal Shield Flexures and Support Block Cap Screw Degradation

• Reviewed previous Unit-2, VT-3 of Thermal Shield Flexures

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 2J Safety Bus Loss of Offsite Power and Loss of Coolant Accident Testing during low time to boil and high decay heat load early in the 2R29 refueling outage, on May 5, 2020.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Service water strainers, 1-VS-S-1A and 1-VS-S-1B, and associated support structures on May 21, 2020

Aging Management (IP Section 03.03) (1 Sample)

The inspectors evaluated the effectiveness of the aging management program for the following SSCs that did not meet their inspection or test acceptance criteria:

(1) Fire protection program as associated with the buried piping aging management programs following multiple identified failures and leaks, on April 7, 2020

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) Units 1 and 2 elevated risk for a heavy lift near the 'C' reserve station service transformer overhead cables, on April 16, 2020.

(2) Unit 2 elevated risk for solid plant operations during 2R29 reactor coolant system (RCS) cleaning window followed by low time to boil, on May 4 and 5, 2020.

(3) Unit 2 crane lift path near residual heat removal system piping, on May 6, 2020.

(4) Unit 1 increased online risk and Unit 2 increased shutdown risk following the rupture of a portion of the fire protection loop piping, on May 8, 2020.

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

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

(1) Deferral of corrective maintenance to replace a leaking clutch on the Unit 2 'A' containment spray pump from the Unit 2 refueling outage, on April 28, 2020.

(2) Low differential pressure associated with the 'A' residual heat removal pump identified during surveillance testing, on May 5, 2020.

(3) CR1146455, inspector identified unusual indications on the pressurizer relief tank rupture discs, on May 5, 2020.

(4) CR1148965 and CR1149855, auxiliary feedwater pump seal leakage at Units 1 and 2, on June 8, 2020.

(5) CR1149697, lift of the Unit 1 'B' safety injection accumulator tank relief valve during pressurization in support of tank sampling, on June 12, 2020.

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (3 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Addition of a solenoid operated valve on both Unit 2 pressurizer spray valve actuators in the 2R29 refueling outage, on May 30, 2020.

(2) Change in fire protection piping joint restraints between fire water isolation valves, 1-FP-92 and 1-FP-41, during piping replacement under ETE-SU-2020-0025, Joint Restraints on Fire Protection Piping Between Valves 1-FP-92 and 1-FP-41, Revision 0, on May 15, 2020.

(3) Use of degraded 'B' pressurizer safety relief valve as an RCS pressure boundary on Unit 2 during solid plant operations implemented under SU-20-00145, on May 28, 2020.

Severe Accident Management Guidelines (SAMG) Update (IP Section 03.03) (1 Sample)

(1) Verified the site Severe Accident Management Guidelines were updated with the PWR Owner's Group revised generic severe accident technical guidelines in accordance with the processes in NEI 14-01, Revision 1, and verified the revised guidelines were reviewed through tabletop exercises to confirm clarity of transitions and strategies, on May 1, 2020.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) Troubleshooting and restoration of the reactor vessel standpipe for drain down level indication, on May 6, 2020.

(2) 2-OPT-FW-001, Motor Driven Auxiliary Feedwater Pump 2-FW-P-3A following maintenance on the 2H emergency bus and the pump's recirculation check valve, on May 12, 2020.

(3) 'C' reserve station service transformer cable tan delta testing following cable replacement, on May 13, 2020.

(4) Replacement of the 2B pressurizer safety relief valve following human performance error during heavy lifting, WO 38204220810, on May 26, 2020.

(5) Troubleshooting and restoration of the 1B feedwater regulating valve controller after unexpected operation, CR1149428, on June 9, 2020.

(6) Unit 2 Turbine Drive Auxiliary Feedwater Pump Turbine and Turbine Shaft following identification of pitting, CR1147392, requiring corrective maintenance, June 10, 2020.

(7) Packing adjustment on the 1B motor driven auxiliary feedwater pump to address leakage and spray under WO 38204208746 on June 11, 2020.

71111.20 - Refueling and Other Outage Activities

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

(1) The inspectors evaluated Unit 2 outage 2R29 activities from May 3, 2020, to June 6, 2020.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) 2-OPT-ZZ-002, ESF Actuation with Undervoltage and Degraded Voltage at the 2J Safety Bus, on May 5, 2020.

(2) 2-OPT-FW-001, Motor Driven Auxiliary Feedwater Pump 2-FW-P-3A, on

===June 8, 2020.

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

(1) 2-OPT-RH-003, RHR System Operability Test, on May 3, 2020.

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

(1) 2-OSP-SI-013, Determination of High Head Safety Injection Containment Isolation Valve Leakby, on May 30, 2020.

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04) (1 Sample)

(1) The inspectors evaluated the maintenance and testing of the alert and notification system during the week of June 22, 2020.

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02)

The inspectors evaluated the readiness of the Emergency Response Organization (ERO)during the week of June 22, 2020. However, the inspectors were unable to complete this inspection procedure (IP) in its entirety. The aspect that remains to be inspected is the verification of a sample of key ERO personnels training qualifications and response times from home to the site. The necessary documentation used by the inspectors to verify this information is considered personally identifiable information, which the inspectors chose not to handle while performing this inspection remotely. The remainder of this IP will be completed at a later date.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated submitted Emergency Action Level (EALs), Emergency Plan, and Emergency Plan Implementing Procedure changes during the week of June 22, 2020. This evaluation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11)

The inspectors evaluated the maintenance of the emergency preparedness program during the week of June 22, 2020. However, the inspectors were unable to complete this IP in its entirety. The aspects that remain to be inspected are the verification of radiation monitors used in the EALs to ensure proper scale readout of the instrumentation, emergency response facilitys readiness, including field monitoring team vehicles and go-kits used for emergencies. The remainder of this IP will be completed at a later date.

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated a licensee emergency planning drill in the simulator and technical support center, on June 16, 2020. The drill involved the sequential loss of two barriers fuel cladding and RCS with associated emergency classification declarations and protective action recommendations from notice of unusual event to alert to general emergency with a focus on the impact of COVID-19 precautions on emergency plan implementation.

71124.05 - Radiation Monitoring Instrumentation

Calibration and Testing Program (IP Section 03.02) (14 Samples)

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

(1) High Purity Germanium Detector Serial Number 60-TP-24305A , Calibration Date:

04/29/2020

(2) APEX-In Vivo Whole Body Counter Serial Number JO-938 and JO-939, Calibration Date: 09/20/2019

(3) 3110TR Liquid Scintillation Counter Serial Number 433977, Calibration Date:

10/21/2019

(4) MGP Instruments AMP-100 Serial Number 5001-061, Calibration Dates: 10/04/2017 and 05/17/2019

(5) MGP Instruments AMP-200 Serial Number 7708-037, Calibration Dates: 06/29/2016 and 01/08/2018

(6) MGP Instruments Telepole Serial Number 6605-069, Calibration Dates: 03/15/2018 and 02/19/2020

(7) Thermo Scientific RO2AA Serial Number 01194, Calibration Dates: 04/16/2018 and 06/13/2019

(8) Far West Technologies REM500B Serial Number 224, Calibration Dates: 10/08/2018 and 07/16/2019

(9) Eberline AMS-4 Serial Number 630, Calibration Dates: 01/16/2019 and 01/22/2020

(10) Canberra ARGOS-5PAB Serial Number 1112-247, Calibration Dates: 04/24/9019 and 04/16/2020

(11) Canberra GEM-5 Portal Monitor Serial Number 1604-047, Calibration Dates:

06/28/2018 and 07/01/2019

(12) Canberra Cronos Contamination Monitor Serial Number 1303-068, Calibration Dates:

06/26/2018 and 06/07/2019

(13) Victoreen Containment High Range Monitor 2RM-RMS-228, Calibration Dates:

05/18/2017 and 11/01/2018

(14) Victoreen Containment High Range Monitor 2RM-RMS-227, Calibration Dates:

05/08/2017 and 11/01/2018 Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (3 Samples)

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

(1) Unit One Process Vent Normal and High Range Effluent Radiation Monitor, 1-GW-RM-130

(2) Unit One Radwaste Facility Liquid Effluent Monitor, 1-RR-RRM-RITS-131

(3) Unit One Ventilation Vent No. 2 Particulate and Gas Monitors, 1-VG-RM-131A, 131B and 131C

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

EP01: Drill/Exercise Performance (IP Section 02.12) ===

(1) April 1, 2019, through March 31, 2020.

EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)

(1) April 1, 2019, through March 31, 2020.

EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)

(1) April 1, 2019, through March 31, 2020.

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

(1) September 2019 to March 2020 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) September 2019 to March 2020

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)

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

(1) Operational Experience Smart Sample 2007/03, Crane and Heavy Lift Inspection, Supplemental Guidance to IP 71111.20 and IP 71111.13, for lifts inside the Unit 2 containment during the refueling outage.

71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000280, 281/2019-002-00, Items Non-Conforming to Design for Tornado Missile Protection, (ADAMS Accession No. ML20054A141). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section

INSPECTION RESULTS

Lift of Surry Unit 2 B Pressurizer Safety Relief Valve while Partially Installed in System Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71152 Systems NCV 05000281/2020002-01 Complacency Open/Closed A self-revealing Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was observed associated with the licensees inability to accomplish an activity affecting quality, the lifting and rigging of the Unit 2 B pressurizer safety relief valve, in accordance with documented instructions and procedures, 0-MCM-0424-02, Pressurizer Safety Valve Installation, and GMP-001, Heavy Load Rigging and Movement. This resulted in damage to the valve and adverse impact on the decay heat removal key safety function while in cold shutdown from May 25, 2020, through May 29, 2020.

Description:

On May 25, 2020, with Unit 2 in cold shutdown, maintenance personnel were assigned and briefed to install the safety-related 2-RC-SV-2551B, Unit 2 'B' pressurizer safety relief valve. This evolution was scheduled for less than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, during which the decay heat removal key safety function shutdown risk state would be Yellow due to the loss of the additional backup decay heat removal function provided by reflux cooling/gravity feed &

bleed. Licensee procedures 0-MCM-0424-01, Removal of Pressurizer Safety Valves, and 0-MCM-0424-02, Pressurizer Safety Valve Installation, govern the removal and installation of associated valves. These procedures direct the use of Surry site-specific procedure GMP-001, Heavy Load Rigging and Movement, which in turn incorporates MA-AA-101, Lifting and Material Handling, the fleet level procedure for support of the activity. During the initial attempt to install the relief valve inlet and outlet studs, it was identified that one set of threads was galled. Corrective maintenance would require valve removal and machinist support to rework the threads. Technicians began the process of removing the installed studs from the safety valve. However, they failed to account for 1 of the 12 studs installed at the valve inlet flange.

As the task shifted from installation to removal, a Rigger in Charge (RIC) was identified to direct the work. The RIC established a rigging crew of qualified individuals and set about connecting the equipment and material required to move the valve using a chain fall and slings attached to the polar crane. While the crew performing the lift completed a pre-job brief for the purpose of installing the relief valve, there was a failure to perform a pre-job brief in accordance with GMP-001, step 3.8, bullet 5 for the changed work scope to remove the valve and affect additional maintenance. Pre-job brief sub-bullet 4 specifically ensures the identification of load interferences. The rigging crew did not identify that 1 of the 12 studs remained installed at the valve inlet flange. Additionally, the maintenance crew failed to engage Dominion supervision in advance of the lift.

At approximately 1040, the riggers attempted to lift the valve. The lift was stopped by the failure of the chain fall chain. The links were reported as stretched and broken. Witnesses observed the valve lift at least one-half of an inch, then fall and twist on the inlet flange as it landed. No one was injured as a result of the event. Based upon input from the valve vendor, the relief valve was declared inoperable and non-functional due to the potential for internal damage and misalignment of the seats and connecting subcomponents.

As a result of this human performance event, the reflux cooling/gravity feed & bleed function remained unavailable rendering the decay heat removal key safety function in an elevated shutdown risk state, Yellow, until installation of a new safety relief valve on May 29, 2020.

Corrective Actions: Dominion Energy performed a human performance review board and level of effort evaluation associated with the human performance event. With respect to the equipment reliability impact, the licensee performed engineering inspections of the effected piping, supports, and flange faces as well as installed a replacement safety relief valve.

Corrective Action References: CR1148304, CA8045887

Performance Assessment:

Performance Deficiency: Inspectors found that Dominion Energys failure to perform a pre-job brief identifying load interferences in accordance with GMP-001 and 0-MCM-0424-02 was a performance deficiency reasonably within the licensees ability to foresee and prevent. This resulted in the failure to recognize that the unit 2 B Pressurizer Safety Relief Valve remained partially installed during the lift. This caused damage to the valve and the extended the loss of the additional backup decay heat removal reflux cooling/gravity feed & bleed function from less than 4-hours to May 25, 2020 through May 29, 2020.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human 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. This finding was more than minor in accordance with IMC 0612, Issue Screening, Appendix B, Additional Issue Screening Guidance, dated January 1, 2020, as it represented an adverse impact to the Human Performance attribute of the Reactor Safety -

Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The availability and capability of the decay heat removal key safety function was adversely affected by the extended loss of the additional backup decay heat removal reflux cooling/gravity feed & bleed function. The More than Minor Example 4.b of IMC 0612, Appendix E, Examples of Minor Issues, dated January 1, 2020, was used to inform the answer to the more than minor screening questions. Consistent with example 4.b, the described performance deficiency is not minor as the extended loss of the reflux cooling/gravity feed & bleed function was a challenge to the decay heat removal key safety function during shutdown.

Significance: The inspectors assessed significance of this rigging and lifting event in accordance with IMC 0609, Appendix G, Shutdown Operations Significance Determination Process, Attachment 1, Exhibit 3, Mitigating Systems Screening Questions, Section A. The inspectors determined that this finding required a Phase 2 detailed risk evaluation or analysis as it represented an actual loss of safety function, reflux cooling/gravity feed & bleed function, of one or more non-TS Trains of equipment during shutdown, in cold shutdown, designated as risk significant, associated with a change in decay heat removal key safety function shutdown risk state, for greater than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

A regional senior reactor analyst (SRA) conducted a detailed risk assessment using NRC Inspection Manual Chapter 0609 Appendix G, Attachment 2, Phase 2 Significance Determination Process Template for PWR During Shutdown, dated January 8, 2020. The SRA observed the unit had been shut down for 22 days, and the plant was in POS II in the late time window when the condition occurred on May 25, 2020. The reactor coolant system was vented from May 25 until May 29, and primary means of decay heat removal was from A RHR. The condition affects the backup decay heat removal of reflux cooling/gravity feed &

bleed, due to adversely impacting the vent path used. The SRA determined that in POS II, the conditional finding only affected gravity feed mitigating function in a Loss of Offsite Power (LOOP). Using Worksheet 4, SDP for a PWR Plant - Loss of Offsite Power in POS 2 (RCS Vented), and one path of gravity feed and bleed (GRAV) was not considered available. The SRA concluded the performance deficiency represented finding of very low safety significance (Green).

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. This finding in accordance with IMC 0310, Aspects within the Cross-Cutting Areas, dated December 04, 2014, has a cross-cutting aspect in the Human Performance cross-cutting area associated with Avoid Complacency, in that Dominion Energy individual contributors failed to perform a thorough review of the work site and planned activity when the scope of work for the B Pressurizer Relief Valve changed relying on assumed conditions.

Enforcement:

Violation: 10 CFR Part 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings, states in part, Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, on May 25, 2020, during performance of rigging and lifting of the unit 2 B pressurizer safety relief valve, Dominion Energy did not accomplish the quality related activities as prescribed in 0-MCM-0424-02, Pressurizer Safety Valve Installation, and GMP-001, Heavy Load Rigging and Movement. This resulted in damage to the valve and adverse impact on the decay heat removal key safety function while in cold shutdown.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Enforcement Enforcement Action EA-20-096: Items Non-Conforming to 71153 Discretion Design for Tornado Missile Protection

Description:

During evaluation of protection for TS equipment from the damaging effects of a tornado generated missile in response to Regulatory Information Summary 2015-06, Tornado Missile Protection, Dominion Energy determined that non-conforming conditions with respect to design existed for multiple systems, such that a tornado-generated missile could strike resulting in a substantive adverse effect upon safety across both units. The affected locations were component cooling water piping for the A spent fuel cooling water system heat exchanger; component cooling water pump discharge piping; emergency service water pumps and fuel oil supply tank; service water supply valves to the river make-up pump; and auxiliary feedwater pump suction and discharge piping. The licensee first informed the NRC of this issue in EN#54437 dated December 11, 2019.

Corrective Actions: In accordance with the guidance in Regulatory Issues Summary 2015-06, Tornado Missile Protection, and EGM 15-002, Enforcement Discretion for Tornado Generated Missile Protection Non-Compliance, Revision 1, Dominion Energy implemented compensatory measures to maintain the equipment in a non-conforming but operable condition. These actions included verifying that procedures, training, and equipment were in place to take appropriate action in the event of a tornado watch or warning and establishing a heightened level of awareness and preparedness to tornado missile vulnerabilities.

To restore full compliance, Dominion Energy evaluated the vulnerabilities utilizing approved methodologies in accordance with Timely Resolution of Issues Related to Tornado-Missile Protection Supplemental Information (ML20015A299) dated February 7, 2020, as documented in ETE-SU-2019-0065 and associated revisions to the updated final safety analysis report delineated in SPS-UCR-2019-010. These actions were completed per the timeline established in Enforcement Guidance Memorandum 15-002, Revision 1.

Corrective Action References: CR1137725, CA7801866

Enforcement:

Significance/Severity: A risk evaluation was performed, and the issue was determined to be of very low safety significance (Green).

Violation: A finding and an associated violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, was identified due to a non-conformance with tornado missile protection as described in Chapter 15 of the Surry Power Station Updated Final Safety Analysis Report. This condition also resulted in violations of Technical Specifications 3.0.1 for component cooling water and service water systems and 3.6.F.3 and 3.6.I.2 for auxiliary feedwater systems.

Basis for Discretion: The NRC exercised enforcement discretion in accordance with Section 2.3.9 of the NRC Enforcement Policy and is not issuing enforcement action because this finding and violation was identified during the discretion period covered by Enforcement Guidance Memorandum 15-002, Enforcement Discretion for Tornado Missile Protection Non-compliance, Revision 1 and because Dominion Energy has implemented appropriate compensatory measures.

The disposition of this violation closes LER 05000280, 281/2019-002-00, Items Non-Conforming to Design for Tornado Missile Protection.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On July 16, 2020, the inspectors presented the integrated inspection results to Mr. Doug Lawrence, then Plant Manager, current Site Vice President, and other members of the licensee staff.

• On May 8, 2020, the inspectors presented the Radiation Safety inspection results to Fred Mladen, former Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures 0-OP-ZZ-021 Severe Weather Preparation 24

71111.04 Drawings 11448-FB-3A SH- Yard Water and Fire Protection Lines 027

001

11448-FB-46A Emergency Diesel Generator #1

11448-FE-1A Main One Line Diagram 047

11448-FE-1A2 Electrical Power Distribution One Line Integrated Schematic 044

SH-001

11548-FM-087A Residual Heat Removal 018

71111.05 Fire Plans 0-FS-FP-161 Auxiliary Building Elevation 27 feet 6 inches 2

0-FS-FP-198 Diesel Fire Pump Room 002

1-FS-FP-168 Turbine Building Basement - Unit 1 002

2-FS-FP-134 Containment Unit 2 001

2-FS-FP-168 Turbine Building Basement - Unit 2 002

71111.06 Engineering Internal Flooding Surry Nuclear Power Plant Units 1 & 2 for Individual Plant November

Evaluations Analysis Examination 1991

Supplemental

Report

71111.08P

Corrective Action CA-7432365 Document retrieval of loose parts IAW SG SSI inspection plan, 11/9/18

Documents Unit 2 steam generator 2-RC-E-1C

CA-7676845 Thermal Shield Attachment Bolts 9/5/19

CR-1109277 ACE CA3064969 Postulated Failure Mechanism not fully 11/1/18

supported by Failure Analysis

CR-1109870 Unit 2, SG C, a total of 16 loose parts were identified and are 11/7/18

being tracked

CR-1114684 Low UT Thickness Reading Identified on Service Water Piping 1/24/19

CR-1132653 Ultrasonic Testing (UT) instrument found to be outside 10/07/2019

equivalency tolerance

CR-1134736 NSAL-05-02 Steam Generator Cover Plate Stress Report 10/31/19

Error

CR-1139625 NRC Concern with ASME Code Compliance of ISI Ultrasonic 01/16/2020

Examination Procedure at non-Dominion Site

CR-1141477 EPRI has issued Interim Guidance Letter SGMP-20-03 2/18/20

PA-3142235 Incorporate NEI 03-08 Guide Card Interim Guidance in the 2/26/18

next required AMP update (SPS) (Ref. LTR-RIDA-17-270 Rev.

1/OG-18-46)

Corrective Action PA-7920671 Program Improvement Action Item to Update ER-SU-AUG-101 5/5/20

Documents to most current revision of N-729 edition

Resulting from

Inspection

Engineering 51-9307723 Surry Unit 2 - 2R29 SG ECT Inspection Plan

Evaluations ETE-CEP-2020- Steam Generator Degradation Assessment Surry Unit 2 3/6/2020

1002 Refueling Outage 2R29

ETE-SU-2018- Steam Generator Condition Monitoring and Operational 11/19/18

0043, Attachment Assessment Surry Unit 2 Refueling Outage EOC28

Westinghouse Westinghouse NSSS PWR Thermal Shield Degradation, 10/9/19

Technical Bulletin Flexures and Support Block Cap Screws

(TB) -19-5

Miscellaneous Curtis-Wright Supplemental NDE Personnel Certification Review Checklist 3/12/20

NDE ID, 000-00-

2442

Curtis-Wright Supplemental NDE Personnel Certification Review Checklist 3/12/20

NDE ID, 000-00-

5354

Curtis-Wright Supplemental NDE Personnel Certification Review Checklist 4/29/20

NDE ID, 000-00-

5711

Curtis-Wright Supplemental NDE Personnel Certification Review Checklist 3/12/20

NDE ID, 000-00-

8733

EPID N

O. L-2019- Virginia Electric and Power Company, Docket No. 50-281, 5/7/20

LLA-0071 Surry Power Station, Unit No. 2, Amendment to Renewed

Facility Operating License, Amendment No. 299, Renewed

License No. DPR-37

FABP--MSWQC- Krautkramer Transducer, Certificate of Conformity, Compliant 3/3/08

BMC 5.0X.25, SN to ASTM E-1065 Guidelines

SC0079

71111.08P

Miscellaneous NDE NDE Qualification and Certification Record, Jurewicz 1/24/20

Qualifications,

VT-1, VT-2, VT-3

NDE Visual Jurewicz Visual Acuity 10/7/19

Qualification

SAR002813 Boric Acid Corrosion Control (BACC) Program Self- 12/16/14

Assessment

Surry Tech Specs Steam Generator (SG) Program, Amendment 278 1/28/13

6.4.Q

Welder ID RC- Welder Qualification for WO 38103681988 2/10/16

26 7, N- 240

Westinghouse Reactor Vessel Head Control Rod Drive Mechanism 2/14/20

NSAL-20-1 Penetration Thermal Sleeve Cross-Sectional Failure

NDE Reports MT-20-001 Magnetic Particle Examination, Pressurizer Skirt Weld 5/12/20

BOP-PT-17-096 Work Order 38103681988, Welds 2 thru 12, and 15 thru 17 12/5/18

Final Penetrant Test

BOP-PT-18-253 WO 38103681988, F Penetrant Test Final Welds 1 AND 13 12/5/18

ETE-SU-2014- Unit-2, Reactor Internals Examination: Reactor Core Barrel 5/16/14

0033 Weld Exams and Balance MRP -227-A Examinations

(Including Thermal Shield Flexures)

MT-20-001 Component ID-11548-WMKS-RC-E-2 / 1-08, Pressurizer Skirt 5/12/20

Weld, Magnetic Particle Examination

PT-20-003 Component ID, 11548-WMKS-0125A1 / 4-RC-314 / 1-10, Pipe 5/11/20

Bend to Pipe

UT-20-004 Component 11548-WMKS-0125A1 / 4-RC-314 / 1-10, Pipe 5/11/20

Bend to Pipe

UT-20-005 Ultrasonic Examination of Component ID, 11548-WMKS- 5/11/20

25A1 / 4-RC-314 / 1-07, Pipe to Bent Pipe

VT-20-032 Owner Elected, VT-2 Leakage Exam of Lower Reactor Nozzle 5/5/20

Penetrations, WO 38204198408/NDER20-002, IAW ER-AA-

NDE-VT-602

Procedures 0-OSP-RC-002 Steam Generator Primary to Secondary Leakage Monitoring Rev. 19

2-NPT-RC-002 BACC INSPECTION OF CLASS 1 BOLTED CONNECTIONS Rev. 8

ER-AA-NDE-MT- Dry Magnetic Particle Examination Procedure Using Yokes Rev. 8

200

ER-AA-NDE-PT- NDE-Visible Solvent Removable Liquid Penetrant Examination Rev. 10

300 Procedure

71111.08P Procedures ER-AA-NDE-UT- Ultrasonic Examination of Austenitic Piping Welds in Rev. 7

2 Accordance with ASME

Section XI, Appendix VIII

ER-AA-NDE-VT- VT-2 Visual Examination Procedure Rev. 6

2

ER-AA-NDE-VT- Visual Examination (VE) for Leakage of PWR Reactor Head Rev. 4

604 Penetrations

ER-AP-BAC-10 Boric Acid Corrosion Control Program Rev. 13

ER-SU-AUG-101 Surry Augmented Inspection Program Rev. 20

Work Orders WO 38103681988 Valve 02-CH-297 Replacement 7/12/18

71111.11Q Procedures 2-OPT-ZZ-002 ESF Actuation with Undervoltage and Degraded Voltage at the Performed

2J Safety Bus May 5, 2020

71111.12 Corrective Action CR1053286

Documents CR1131702

CR1144340

CR486517

Corrective Action CA7872412

Documents CA7872415

Resulting from CR1148066,

Inspection 11446745

71111.13 Miscellaneous Heavy Lift Risk Mitigating Actions for Lift Over RHR Piping 5/6/2020

Surry PRA Risk Evaluation and Risk Mitigating Actions for 4/16/2020

April 16, 2020

Surry PRA Risk Evaluation for May 8, 2020 05/08/2020

Surry Unit 2 Shutdown Risk Assessment for May 4 and 5,

20

71111.15 Corrective Action CR1146181

Documents CR1149697

71111.18

Engineering SU-19-01076 Pressurizer Spray Valve SPV Elimination Unit 2 2

Changes

Miscellaneous 50.59 Screening Document for Implementation of the 01/11/2019

Enhanced Generic SAMG issued by the PWROG

71111.18 Miscellaneous Facility Safety Review Committee Agenda and Notes for 01/17/2019

Approving All SAMG Updates

71111.18 Miscellaneous PWROG SAMG versus WOG SAMG Cross Reference

Document (non-Quality record / no date)

71111.19 Miscellaneous Tan Delta testing results for C RSST replacement cables 04/28/2020

and

05/09/2020

Procedures 2-OP-RC-004 Draining the RCS to Reactor Flange Level 043

71111.20 Miscellaneous RWP 20-0-3533 TEDE ALARA Review for RWP 20-0-3533 03/11/2020

2C30 - Core Reactor Core Video Mapping of New Fuel following Core

Video Mapping Reload

2R29 Pre-Outage Risk Plan

RWP 20-0-3533 High Radiation Area (HRA) Briefing package for RWP 20-0- 03/10/2020

3533

Procedures 2-GOP-1.4 Unit Startup, Hot Shutdown to 2% Power 59

2-GOP-1.8 Unit Startup, Hot Shutdown to Max Allowable Power 53

RP-AA-261 Control of Radiological Diving Activities Revision 2

Radiation Surveys Unit #2 Containment- Transfer Canal Pre-Dive Radiation 05/13/2020

Survey

Radiation Work 20-0-3533 U2R29 - U-2 Containment Diving Activities to Repair Fuel Revision 0

Permits (RWPs) Transfer Equipment and/or Cables

71114.06 Miscellaneous SJUN20 FS Surry Full Scale Drill June 16,

20

Surry EAL Matrices 4

71151

Calculations Sample ID: 27- Gamma Spectrum Analysis Results, Vent 2 Gas 02/27/2020

FEB-2020-0012

Sample ID: 28- Gamma Spectrum Analysis Results, LWMT B 02/28/2020

FEB-2020-0004

Corrective Action CR1131151, CR1131710, CR1132271, CR1132705, Various

Documents CR1132858, CR1133154, CR1134937, CR1135182,

CR1137130, CR1137986, CR1139150, CR1140355,

CR1141408, CR1142421, and CR1142678

Miscellaneous Electronic Dosimeter (ED) Dose and Dose Rate Alarm Logs September

2019 to

March 2020

71151 Miscellaneous Surry Power Station 2018 Annual Radioactive Effluent 04/22/2019

Release Report

Surry Power Station 2019 Annual Radioactive Effluent 04/26/2020

Release Report

Surry Power Station Regulatory Assessment Performance September

Indicators 2019 to

March 2020

Permit # G- Surry Power Station Gaseous Effluent Release Report, Vent 2 03/01/2020

200220-054-C

Permit # L- Surry Power Station Liquid Effluent Release Report, Liquid 02/28/2020

200228-042-B Waste Monitoring Tank B

Sample ID # Surry Power Station 10 CFR Part 61 Radioactive Waste 10/02/2018

L78292-1 Stream Characterization, DAW 2018

Procedures PI-AA-100-1000 Performance Indicators Revision 5

PI-AA-200 Corrective Action Revision 35

RP-AA-112 Radiation Safety Performance Indicator Reporting Revision 4

71152 Corrective Action CA8045887

Documents CR1146573

CR1148304

Engineering ETE-CEM-2020- Evaluation of Pressurizer Safety Valve 2-RC-SV-2551B Inlet Revision 0

Evaluations 0003 Piping and Support Structure for Loading experienced during a

Rigging Event Documented in CR1148304

Miscellaneous 2R29 Outage (a)(4) Risk Evaluation

Procedures 0-MCM-0424-01 Removal of Pressurizer Safety Valves Revision 24

0-MCM-0424-02 Pressurizer Safety Valve Installation Revision 17

1-SAG-1 Main Control Room Severe Accident Guideline Initial 0

Response

GMP-001 Heavy Load Rigging and Movement Revision 38

MA-AA-101 Lifting and Material Handling Revision 26

71153 Engineering ETE-SU-2019- Implementation of Surry Tornado Missile Risk Evaluator Revision 0

Evaluations 0065 Analysis

SPS-UCR-2019- Tornado Missile Risk Evaluator Implementation Revision 0

010

Procedures 0-AP-12.01 Loss of Intake Canal Level Revision 37

0-AP-37.01 Abnormal Environmental Conditions Revision 75

0-OP-FC-002 Spent Fuel Pit Cooler Operations Revision 6

0-VSP-D7 CC SURGE TK HI LO LVL Revision 3

1/2-ES-0.1 Reactor Trip Response Revision

55/57

21