IR 05000281/2020040
| ML20365A007 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/30/2020 |
| From: | Stewart Bailey NRC/RGN-II |
| To: | Stoddard D Virginia Electric & Power Co (VEPCO) |
| References | |
| IR 2020040 | |
| Download: ML20365A007 (18) | |
Text
December 30, 2020
SUBJECT:
SURRY POWER STATION - 95001 SUPPLEMENTAL INSPECTION SUPPLEMENTAL REPORT 05000281/2020040
Dear Mr. Stoddard:
On November 20, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed a supplemental inspection using Inspection Procedure 95001, "Supplemental Inspection Response to Action Matrix Column 2 Inputs, and discussed the results of this inspection and the implementation of your corrective actions with Mr. Lawrence and other members of your staff at an exit and regulatory performance meeting on November 20, 2020.
The NRC performed this inspection to review your stations actions in response to a White finding in the Mitigating Systems cornerstone which was documented and finalized in NRC Inspection Report 2020091. On October 8, 2020, you informed the NRC that your station was ready for the supplemental inspection.
The NRC determined that your staffs evaluation identified the cause of the finding. Specifically, The NRC determined your staffs evaluation identified the primary root cause as non-conservative interpretation of site procedures and industry guidance used during development of the check valve condition monitoring program. The root cause had three contributing causes related to a lack of interface between programs, a lack of process to drive review of monitoring plans following corrective maintenance, and inconsistent documentation of maintenance patterns and failure mechanisms. In addition, your staff performed an evaluation for the inoperability of the auxiliary feedwater system in which it identified the root cause to be inadequate preventive maintenance due to cancelation of work activities to open and inspect the Unit 2 turbine-driven auxiliary feedwater (TDAFW) pump discharge check valve 2-FW-142. The extent of conditions was determined to potentially affect all check valves in the in-service test program and check valves in similar applications. The corrective actions to prevent recurrence include replacement of pump and valve components in the Unit 2 TDAFW system, intrusive inspections (disassembly of affected check valves to look for wear or degradation), updates to fleet procedures, creation of recurrent maintenance tasks for the affected valves, interim acoustic testing, and updates to check valve monitoring plans that will also validate requirements of American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code, Mandatory Appendix II, "Check Valve Condition Monitoring Program," are met.
The NRC determined that completed or planned corrective actions were sufficient to address the performance issue that led to the White finding. Therefore, the performance issue will not be considered as an Action Matrix input after the end of the first quarter of 2021. Based on the results of this inspection and our Action Matrix assessment, the NRC has determined that Surry Power Station Unit 2 will transition to the Licensee Response Column (Column 1) of the Action Matrix on April 1, 2021, considering no additional Action Matrix inputs occur.
No findings or violations of more than minor significance were identified during this inspection.
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 No. 05000281 License No. DPR-37
Enclosure:
As stated
Inspection Report
Docket Number: 05000281 License Number: DPR-37 Report Number: 05000281/2020040 Enterprise Identifier: I-2020-040-0004 Licensee: Virginia Electric and Power Company (Dominion Energy)
Facility: Surry Power Station Location: Surry, VA Inspection Dates: November 16, 2020 to November 20, 2020 Inspectors: K. Carrington, Resident Inspector T. Scarbrough, Senior Mechanical Engineer M. Schwieg, Reactor 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 a 95001 supplemental 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
No findings or violations of more than minor significance were identified.
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, conducted walkdowns, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
===95001 - Supplemental Inspection Response to Action Matrix Column 2 Inputs The inspectors reviewed and selectively challenged aspects of the licensees root cause analysis, including extent of condition, extent of cause reviews, and corrective actions in response to a White finding and associated Notice of Violation (NOV) of 10 CFR 50.55a(f)(4) for its failure to meet the inservice test (IST) requirements set forth in Mandatory Appendix II, "Check Valve Condition Monitoring Program," of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance (OM) of Nuclear Power Plants. Specifically, the station did not analyze known failure or maintenance patterns of the Unit 2 TDAFW check valve 2-FW-142 to determine their significance and identify potential failure mechanisms. The finding and associated NOV is discussed in NRC Inspection Report and Final Significance Determination Letter 05000281/2020091. The inspectors utilized information in root cause evaluation (RCE) reports CA8117061 and CA7783062 to assess whether objectives of the inspection procedure (IP) were met. Highlights of the performance review and NRCs assessment are documented below.
Supplemental Inspection Response to Action Matrix Column 2 Inputs ===
- (1) From November 16, to November 20, 2020, the inspectors conducted an onsite review to verify all aspects of the inspection procedure were met.
INSPECTION RESULTS
Assessment 95001 1. Problem Identification a. Identification On November 20, 2019, during performance of the Unit 1 Auxiliary Feedwater (AFW)
Pump Check Valve Operability test (1-OPT-FW-142), an operator discovered the Unit 2 Turbine-driven auxiliary feedwater (TDAFW) pump rotating in the reverse direction due to excessive back leakage through the Unit 2 TDAFW pump discharge check valve (2-FW-142). Consequently, the Unit 2 AFW system was declared inoperable and deemed incapable of performing its safety function. Within 20 minutes of the event, operators closed the Unit 2 TDAFW manual discharge isolation valves, restoring the safety function to the AFW system. From November 20 to 22, 2019, Unit 2 remained in a 72-hour technical specification (TS) limiting condition of operation (LCO) action statement for inoperability of the TDAFW system. The TS action statement was exited following repairs to the TDAFW pump and turbine bearings and check valve 2-FW-142. The failure of the TDAFW check valve revealed weaknesses in the stations preventive maintenance (PM) and check valve condition monitoring (CVCM) programs since its establishment which ultimately led to an NRC-identified finding for the failure to meet the inservice test (IST) requirements of the ASME OM Code. The licensee documented that the lack of a rigorous review and challenge of legacy decisions made prior to and during inception of its CVCM program contributed to its failure to identify the performance issue.
b. Exposure Time and Identification Opportunities The root cause evaluations (RCEs) documented a potential for failure of the Unit 2 TDAFW check valve 2-FW-142 had existed since the preventive maintenance (PM)requirement to periodically disassemble and inspect the valves internals for wear and degradation was first cancelled in 1996. From 1996 to 2004 (when the station adopted its CVCM program) and thereafter, Surry relied on periodic leakage testing to monitor the internal condition of the valve. The licensees procedure at the time considered disassembly and inspection appropriate for valves that couldnt be tested under design bases conditions. In the RCE, the licensee stated that check valve disassembly inspections would be performed if other testing options were unavailable. In RCE CA8117061, the licensee identified conflicting industry guidance documents were referenced in the procedure. For example, EPRI document NP-5478, Application Guide for Check Valves in Nuclear Plants, warned that leakage tests may not give indication of impending failures while a Nuclear industry check valve users group (NIC) document indicated leakage tests were good predictors of future failures from hinge pin wear and valve degradation (the exact failure mechanism of the 2-FW-142 valve). The licensee noted this discrepancy was never addressed in the original procedure and due to the lapse in time could not determine the basis for the PM cancellation or continued acceptance of the leak testing to detect internal valve wear during adoption of its program. The inspectors concluded the RCEs appropriately assessed exposure and identification opportunities.
c. Risk and Compliance Both RCEs documented that the Unit 2 AFW system was declared inoperable and incapable of performing its safety function until the Unit 2 TDAFW manual discharge isolation valves were closed. The RCEs also documented the qualitative consequences of the event and performance issue with respect to nuclear, radiological, safety culture, and industrial consequences. Based on their review, the inspectors concluded the RCEs demonstrated an understanding of significant plant consequences and compliance concerns associated with the event and performance issue.
NRC Assessment: The inspectors review determined the licensees evaluation documented who identified the issues, how long the issues existed, prior opportunities for identification, and the plant-specific consequences of the event. The inspectors had the following observations:
- Neither RCE captured quantitative risk insights related to the performance issue or event.
- The licensees review of CVCM plans did not consider quantitative risk measures of check valves like the failed TDAFW check valve (2-FW-142) which had a high plant risk profile (Birnbaum value greater than1E-6) and resulted in the NRC-issued white finding. The inspectors also identified other high-risk (>1E-6) check valves that were given a low level of concern during the licensee's review.
- While reviewing the past operability evaluations, the inspectors identified another scenario not considered by the licensee involving auto-initiation of all AFW pumps which could render the AFW system inoperable.
- The RCEs placed less emphasis on the fact the TDAFW check valve was identified as being susceptible to excessive leakage and degradation due to its location which caused it to see turbulent flow conditions - the initial basis for the PM that was canceled.
- The inspectors considered that the maintenance and performance history of check valves at Surry provided additional opportunities for the identification of weaknesses in the implementation of the CVCM Program prior to the failure of the TDAFW check valve 2-FW-142. The inspectors reviewed several condition reports related to check valve performance dating back to 2006 that confirmed prior opportunities existed for the identification of weaknesses in the CVCM Program. These were not referenced in the licensee's RCEs.
2. Root Cause, Extent of Condition, and Extent of Cause Evaluation.
a. Methodology The licensee employed systematic, evidenced-based methodologies including, Why Staircase analysis, Event and Causal Factors Analysis, Fishbone Analysis, Programmatic and Organizational Chart Analysis, and the Decision-Making Evaluation tool to gather data, identify the problem, and determine the root cause and contributing causes of the White finding and AFW system inoperability.
- RCE CA8117061 identified the root cause as non-conservative interpretation of site procedures and industry guidance documents used during development of the CVCM Program that resulted in a bias by licensee personnel that leak testing was a reliable predictor of future check valve failures associated with hinge pin wear and other valve degradation of the closed obturator position changing relative to the valve seat. This RCE listed three contributing causes:
- (1) no process link between the CVCM program and preventive maintenance program;
- (2) no process driven mechanism to initiate a review of the check valve condition monitoring plan in accordance with ASME OM Code, Appendix II, when corrective maintenance was performed; and
- (3) CVCM plans inconsistently document the basis for the decisions made related to maintenance patterns and failure mechanisms during initial development.
- RCE CA7783062 identified the root cause of the inoperability of the AFW System as inadequate preventative maintenance of the TDAFW check valve 2-FW-142 as a result of decisions in 1996 and 2005 to cancel work orders to disassembly and inspection of the check valve and to place the preventive maintenance in an On Demand status. During the inspection, the licensee stated that the performance of an open/inspect activity for a valve in the On Demand status meant that its inspection depended on the identification of a performance issue with the valve. This RCE did not list any contributing causes for the valve failure.
b. Level of Detail The inspectors determined the RCEs, in aggregate, were performed to a level of detail commensurate with the safety significance and complexity of the performance issue and was of sufficient detail to identify the root and contributing causes, extent of conditions, and extent of causes. The RCE teams utilized a formal cause analysis process to identify the problems and determine corrective actions. The RCEs were performed by individuals in the licensees organization with varying levels of experience and backgrounds. The licensee also utilized an independent contractor during development of RCE CA8117061 to perform a review and assessment of its CVCM program and aid in its identification of extent of condition, extent of cause, and corrective actions.
c. Operating Experience The inspectors noted RCE8117061 accounted for prior occurrences of the performance issue and check valve failure throughout the industry and at the site. RCE CA8117061 identified applicable industry operating experience in NRC Information Notice 2000-21, Detached Check Valve Disk Not Detected by Use of Acoustic and Magnetic Non-intrusive Test Techniques, which describes the exact valve failure at another site related to non-intrusive tests failing to identify significant check valve degradation. The inspectors concluded the licensee appropriately considered prior occurrences and operating experience.
d. Extent of Condition and Cause Based on their separate root cause determinations, RCEs CA7783062 and CA8117061 included different evaluations of the extent of condition and extent of cause for the TDAFW check valve 2-FW-142 failure. In RCE CA7783062, the licensees extent of condition evaluation for the TDAFW check valve failure focused on safety-related swing check valves without an open/inspect PM that are subject to excessive wear. This extent of condition also included the opposite units TDAFW pump discharge check valve, both units motor driven AFW pump discharge check valves, and both units high head safety injection charging pumps discharge check valves due to a similar configuration to the AFW system. RCE CA8117061 provided a broader evaluation of the cause of the failure of the check valve from a programmatic perspective. RCE CA8117061 specified that the extent of condition evaluation for the programmatic issue was bounded to all check valves in the IST Program. RCE CA8117061 also specified the extent of cause was bounded to other components in the IST Program, including pumps, valves, check valves, pressure reducing devices, and dynamic restraints (snubbers). RCE CA8117061 also indicated that all IST procedures were reviewed against the ASME OM Code requirements, with a representative sample (approximately 10 percent) of the components from each program reviewed to ensure that monitoring of the components was being performed in accordance with site and fleet procedures. The RCE documented that a 100 percent review of all IST check valves at the site was conducted, and a 100 percent review of the snubber maintenance and inspection history will be conducted as a follow-on action. The inspectors concluded the licensee appropriately identified the extent of condition and extent of cause.
e. Safety Culture The inspectors reviewed the safety culture components referenced in NUREG-2165, Safety Culture Common Language, to determine if these were appropriately considered during the licensees evaluations of the root causes, extent of conditions, and extent of causes.
NRC Assessment: The inspectors review determined the licensees evaluations were documented at a sufficient level of detail, included relevant operating experience, and identified the root causes, contributing causes, extent of conditions, and extent of causes of the performance issue and event. The inspectors determined the licensees RCEs considered the safety culture aspects related to decision making and questioning attitude. The inspectors had the following observations:
- One or more evaluation tools were lacking in detail and did not have clear logic ties to the root and contributing causes. By the end of the inspection, the licensee provided documentation explaining its thought process and links to the contributing and root causes. The licensee chose to perform a separate root cause to focus on the programmatic failures of compliance with the ASME code however, the inspectors noted it was difficult to determine that no bias existed due to the new root causes team knowledge of CA7783062 results and overlapping details between the two RCEs.
- With respect to operating experience, the inspectors noted the licensees RCE placed less weight related to check valve performance issues at the site, including prior occurrences of excessive valve leakage, degradation, and failures.
3. Corrective Actions
a. Corrective Actions
Taken As discussed in the licensees written response to the NOV and finding, the licensee performed a formal evaluation to determine the root cause of the AFW event that resulted in the stations failure to meet its technical specifications. The evaluation identified inadequate preventive maintenance as the root cause, specified in CA7783062. The inspectors noted all but one corrective action to prevent recurrence of the licensees failure to meet the IST requirements of the ASME code (addressed in CA8117061) were incomplete at the time of the inspection.
The completed corrective actions to address the root cause and technical specification noncompliance for the inoperability of the AFW system included: restoring the AFW system by isolating valves in the TDAFW system, implementing repairs to the Unit 2 TDAFW pump and discharge check valve, verifying a similar failure mechanism identified for the Unit 2 TDAFW check valve was not present in the Unit 1 TDAFW check valve (1-FW-142), and disassembling and inspecting safety-related check valves in similar applications or systems on both units. Additionally, the licensee established recurrent PM activities to inspect the components in the identified valves, and established acoustic monitoring to ensure valve closure following testing.
NRC Assessment: Based on their review, the inspectors determined the corrective actions to prevent recurrence of the AFW inoperability were prioritized with their safety significance and appeared adequate.
- The inspectors determined CA7783062 established qualitative effectiveness measures of success for each corrective action to prevent recurrence.
- The effectiveness measures will involve successful establishment of a PM for each of the recommended valves and maintenance feedback on interim acoustic testing.
b. Corrective Actions
Planned The planned corrective actions to prevent recurrence of the root and contributing causes identified in RCE 8117061 that are related to the licensees failure to meet the IST requirements of the ASME OM code will include:
CAPR-1) updates to the licensees check valve condition monitoring fleet procedure to provide guidance on when to open and inspect valves; CAPR-2) requirement for fleet challenge review when changes to the check valve condition monitoring plan are warranted; CAPR-3) training on when opening and inspection of check valves are required; CAPR-4) incorporation of lessons-learned based on training gap analysis process; CACC-01) updates to inservice test procedure to include guidance to inservice test engineer to review changes through recurrent tasks for inservice test components; CACC-02) updates to include a step for inservice test engineer to initiate a condition report if corrective maintenance was performed or is required, and a significant change is warranted so that a review of the basis in the CVCM plan for the check valve and the associated group or similar groups IAW ASME OM Code Appendix II Section 5000 is performed; and STCA-02) update CVCM plan to include open and inspect where required based on the extent of condition review and validate the updated CVCM program includes all the programmatic requirements from each section in Appendix II of the ASME OM code.
(Revised during inspection).
Additionally, planned corrective actions will include improvements to the licensees CVCM Program and IST Program for other components (such as pumps, snubbers, and other valve types). Revisions to CVCM plans will be prioritized via a tiered approach that is based on risk or ranking of the check valve. Since the majority of corrective actions are not scheduled for completion until December 2021, the inspectors could not evaluate their effectiveness during this inspection. The licensees final effectiveness review will measure success through performance of a self-assessment of its CVCM program. The two-year self-assessment will ensure compliance when establishing or modifying CVCM criteria, the common failures or maintenance patterns are analyzed so that all in-service testing requirements set forth in ASME OM code of record is met and will allow for accumulation of CVCM plan modifications. The inspectors noted the completion date of the effectiveness review was reasonable.
NRC Assessment: The inspectors concluded the dates for implementation and completion of the planned root and contributing cause corrective actions were reasonable, effective, and prioritized with consideration for risk significance and regulatory compliance. The inspectors also concluded the licensee established qualitative measures of success to evaluate the effectiveness of their corrective actions. The inspectors had the following observations:
- The contributing causes appeared to be more reflective of the root cause of the performance issue. However, the licensee maintained that the bias pertaining to leak testing created from the guidance in the procedure resulted in the stations failure to satisfy the monitoring criteria in its program to even consider analyzing common failure or maintenance patterns and determining their significance. The licensees initial planned corrective actions were not clear regarding resolution of the programmatic weaknesses in the CVCM Program at Surry Units 1 and 2. To clarify its ongoing activities, the licensee developed enhancements to its planned corrective actions by revising several actions and establishing a new condition report to provide assurance that the programmatic aspects related to the failure of TDAFW check valve 2-FW-142 will be addressed through redevelopment of its CVCM Program to satisfy the requirements in the ASME OM Code, Appendix II. These enhancements included:
- (1) ensure periodic Engineering training is conducted on the CVCM Program implementation requirements in accordance with the ASME OM Code, Appendix II, CVCM Program (including how to disposition check valve open/inspect inspections as required by station procedures);
- (2) perform a station self-assessment utilizing external peer review of the implementation of the CVCM Program using the ASME OM Code, Appendix II, CVCM Program criteria after completion of planned corrective actions;
- (3) validate that the updated CVCM Program includes all the programmatic requirements from each section of Appendix II; and
- (4) benchmark CVCM Programs at specific nuclear power plants and evaluate for CVCM Program enhancements at Surry. With the enhancements to the planned corrective actions, the inspectors determined that the licensee had established prompt actions to effectively preclude repetition of the significant performance issues related to the failure of TDAFW check valve 2-FW-142 in meeting the ASME OM code requirements.
- The inspectors noted obsolete information in the licensees procedures pertaining to non-intrusive testing methods.
4. Old Design Issue Evaluation The inspectors did not evaluate the finding and associated violation for treatment as an Old Design Issue as it did not satisfy the criteria specified in IMC 0305 Section 11.05.
5. Conclusion The inspectors concluded the corrective actions to preclude repetition of the root and contributing causes of the performance issue and event were effective and adequately prioritized considering safety significance and regulatory compliance. In addition, the inspectors determined the licensee established qualitative measures of success for determining the effectiveness of the corrective actions. Based on the results of the inspections, the inspectors concluded the objectives of the IP were met.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On November 20, 2020, the inspectors presented the 95001 supplemental inspection results to Mr. Doug Lawrence and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
95001 Corrective Action CA7783062 Unit 2 Auxiliary Feedwater System Declared Inoperable 0
Documents 0-MCM-0417-40 Schutte & Koerting Check Valve Inspection and Overhaul 15
0-MCM-0417-45 Vogt Piston Check Valve Inspection and Overhaul 14
CA3003883 Degraded Service Water Conditions Resulted in 0-AP-12
Entry
CA7602259 Effectiveness Review December
2017
CA8085172 Establish open and inspect PMs for leak tested only CVCM 07/16/2020
valves
CA8166324 CAPR-4 Incorporate lessons learned from RCE in Eng 10/12/2020
Continuing Training for Tech Conscience
CA8166328 CACC-03 Update all CVCM plans (Tier 2 att 11) 10/12/2020
CA8166345 Perform Effectiveness Review RCE8117061 10/12/2020
CA8225156 Perform Effectiveness Review of RCE CA7783062 CAPRs 11/10/2020
CR005239 Open and Inspect for IST check valves not performed 12/05/2006
CR005241 Open and Inspect on IST check valves not performed 12/05/2006
CR009004 2-CC-P-2B rotating backwards 03/21/2007
CR009378 Informal IST Self Assessment Item - Check Valve Condition 03/26/2007
Monitoring
CR013522 2007 INPO Plant Evaluation 06/11/2007
CR103245 Critical observation of the inspection of 1-SW-262 07/08/2008.
CR1136400 2-FW-P-2 Rotating in Reverse Drection 11/20/2019
CR1150753 NRC Preliminary White Finding and Apparent Violation 06/30/2020
CR1151793 Boric Acid buildup on 1-CH-133 07/18/2020
CR1152636 Notice of Violation (White) received for 11/19/2019 TDAFW 07/31/2020
pump check valve failure event
CR1155323 0-DRP-012 references 09/14/2020
CR1155531 Check valve condition monitoring plan for U1 group 73 check 09/16/2020
valves not current revision in Doctop
CR1155534 CVCM plans for Group 76 reference a PM strategy that is 09/16/2020
Inspection Type Designation Description or Title Revision or
Procedure Date
CR8166329 STCA-02 Update CVCM Plans (Tier 1 att 1) 10/12/2020
CR8166345 Perform Effectiveness Review RCE8117061 10/12/2020
RCE CA7783062 Unit 2 Auxiliary Feedwater System Declared Inoperable 0
RCE CA8117061 White Finding for 2-FW-142 not Meeting Inservice Testing 0
Requirements of ASME Code
Corrective Action CR 161168 95001 Inspection Identified Cause Evaluation Tools used in 11/19/2020
Documents RCE 8117061 are not Linked to a Cause
Resulting from CR1160995 Grease Leakage out of 1-CH-MOV-1287B operator 11/17/2020
Inspection CR1160997 Packing Leakage at 1-FW-170 11/17/2020
CR1161141 Surry 95001 Supplemental Inspection for the White Finding 11/19/2020
associated with 2-FW-142 CVCM Program
CR1161141 Surry 95001 Supplemental Inspection for the White Finding 11/19/2020
associated with 2-FW-142 CVCM Program
CR1161168 95001 Inspection identified Cause evaluation tools used in 11/19/2020.
RCE 8117061 to a cause
Drawings 11448-FM-068A, Surry Power Station Unit 1 Flow/Valve Operating Numbers 65
Sheet 1 Diagram Feedwater System, Drawing
11448-FM-068A, Surry Power Station Unit 1 Flow/Valve Operating Numbers 30
sheet 1 Diagram Feedwater System
11448-FM-068A, Surry Power Station Unit 1 Flow/Valve Operating Numbers 67
Sheet 3 Diagram Feedwater System Drawing
11548-WMKS- Inservice Inspection Isometric WAPD Sys: Aux. Feed- 5
0118G1-1 Outside Cont. Surry Power Station Unit 2 Virginia Power
Drawing
Miscellaneous Dominion Qualification Record (DQR) DQR-PGM-IST-AA- 3
Fleet Lead/Site Owner
2-FW-142 (AFW Pump 2 Discharge Check Valve) Prior
Operability Review
to 2006
Addenda
System Health Reports, AFW Auxiliary Feedwater (2015 to
20)
Inspection Type Designation Description or Title Revision or
Procedure Date
Check Valve Condition Monitoring Plan Group 1-017a
1-OPT-FW-008 Check Valve Back Leakage Recent History
2-OPT-FW-008 Check Valve Back Leakage Recent History
Phoenix ACT Calculation for 1-OPT-FW-008 11/26/2019
Check Valve Condition Monitoring Plan Group 1-034
Check Valve Condition Monitoring Plan Group 1-047
Surry Power Station Response to Request for Regulatory 07/02/2020
Conference
Surry Nuclear Plant Units 1 & 2, Plan: IST Program Basis 1
Interval 5
Surry Check Valve Condition Monitoring Program Condition 09/10/2020.
Monitoring Plans, Unit 2 Check Valve Groups
Surry Check Valve Condition Monitoring Program Condition 09/10/2020
Monitor Plans, Unit 1 Check Valve Groups
Surry Power Station Unit 1 Inservice Testing Program Plan 8
for Pumps and Valves, Fourth Inspection Interval, May 10,
2004 - May 9, 2014
Surry Power Station Unit 1(2) Inservice Testing Program
Plan for Pumps and Valves, Fifth Testing Interval, May 10,
2014 - May 09, 2024
Check Valve Condition Monitoring Plan Group 1-008
Root Cause Evaluation Quality Index RCE CA8117061 10/02/2020
Surry Power Station Unit 2 Reply to Notice of Violation; EA- 08/28/2020
20-057
LER 05000281- Auxiliary Feedwater Loss of Safety Function due to Check 01/17/2020
2019-002-00 Valve Failure to Close
Vendor Technical Maintenance Manual Cast Steel, Bolted Bonnet, Gate, Globe 4
Manual 38- and Swing Check Valves
W780-00003
Inspection Type Designation Description or Title Revision or
Procedure Date
Vendor Technical The Walworth Company Maintenance Manual Cast Steel 1
Manual 38-W780- Bolted Bonnet Gate, Globe and Swing Check Valves
00002
Virginia Power Develop PM to Open/Inspect the subject check valves on a 02/07/1995
PM Task R03 frequency
Evaluation
Request
MM95013
Procedures 0-MCM-0417-55 Enertech Type DRV-Z Nozzle Check Valve Maintenance 7
0-MCM-0417-60 Pacific Swing Check Valve Inspection and Overhaul 9
0-MCM-0417-70 Newco Check Valve Inspection and Overhaul 6
0-MCM-0417-75 Stockham Swing Check Valve Inspection and Overhaul 7
0-MCM-0417-01 Velan Swing Check Valves Inspection and Overhaul 27
0-MCM-0417-49 William Powell Swing Check Valve Inspection and Overhaul 6
Model 559 & 2433
0-MCM-0417-50 William Powell Swing Check Valve Inspection and Overhaul 8
Model 559 & 2433
0-MCM-0417-52 William Powell Swing Check Valve Inspection and Overhaul 11
Model 2342
0-MCM-0417-55 Enertech Type DRV-Z Nozzle Check Valve Maintenance 7
0-MCM-0417-60 Pacific Swing Check Valve Inspection and Overhaul 9
0-MCM-0417-76 KF Series 10 Check Valve Inspection and Overhaul 6
0-MCM-0417-80 Walworth Swing Check Valve Inspection and Overhaul 7
1-MCM-0417-46 Vogt Model SW-4835 Swing Check Valve Inspection and 8
Overhaul
1-OPT-FW-008 AFW Check Valve Operability Test 24
1-OPT-FW-008, Auxiliary Feedwater Flow Diagram 28
10
2-MCM-0417-80 Westinghouse Swing Check Valve Inspection and Overhaul 6
CM-AA-13 Engineering Program Management 17c
ER-AA-102 Preventive Maintenance Program 13
ER-AA-IST-100 ASME IST Program - General Requirements 4
Inspection Type Designation Description or Title Revision or
Procedure Date
ER-AA-IST-101 ASME IST Program - Inservice Testing of Pumps 4
ER-AA-IST-102 ASME IST Program - Inservice Testing of Valves 6
ER-AA-IST-CKV- ASME IST Program - Check Valve Condition Monitoring 4
104 Program Implementation
ER-AA-IST-VLV- , ASME IST Program - Inservice Testing of Valves 6
2 Implementation
ER-AA-PRS-1001 Plant Health Committee 13
ER-AA-PRS-1003 Equipment Reliability Component Classifications 9
ER-AA-PRS-1010 Preventive Maintenance Task Basis and Maintenance 13
Strategy
ER-AA-SYS-1001 System Health Report 12
MA-AA-VLV-6001 Dominion Fleet Valve Packing Guideline 1
PI-AA-100-1004 Self-Assessments 14
PI-AA-200 Corrective Action 36
PI-AA-300-3001 Root Cause Evaluation 13
PI-AA-300-3004 Cause Evaluation Methods 7
SSES-8.09 Controlling Procedure for the Component Engineering Check 6
Valve Program,
SSES-8.09 Controlling Procedure for the Component Engineering Check 5
Valve Program
Vendor Technical Maintenance Manual Cast Steel, Bolted Bonnet, Gate, Globe 4
Manual VP 38- and Swing Check Valves
W780-00003
WM-AA-100 Work Management 34
WM-AA-100-1003 Work Order Closeout 11
WM-AA-101 Work Order Planning, 20
WM-AA-301 Operational Risk Assessment 20
Self-Assessments 19-07 Inservice Inspection/lnservice Testing & Appendix J and 11/06/2019
North Anna Refueling
PIR 1039265 2016 IST Pump and Valve Self-Assessment 12/15/2016
Work Orders 38204228028 PM: Valve Replacement, 01-CH--109-CKVALV
00456679-10 AFW Pump 2 Disch Chk Valve 03/30/2002
Inspection Type Designation Description or Title Revision or
Procedure Date
3800332715-01 AFW Pump 2 Disch Chk Valve 05/05/1996
38103688622 547 Day Freq. PT: AFW Check Valve Operability - OC-23B 06/07/2017
204178571 91 Day Freq.: IST Guidance for Check Valve Selecting & 12/13/2018
Tracking
204204469 84 Day Freq. PT: Motor Driven Aux. FW Pump 1-FW-P-OC- 05/09/2020
2A
204209889 Open/Inspect/Repair Check Valve 11/21/2019
204209891 Bearing Inspections/Repairs 11/21/2019
204209939 Open/Inspect Check Valve (EOC) 11/21/2019.
204209948 Tack Weld Pin 11/21/2019.
204210572 84 Day Freq. PT: Mtr Driven Aux FW Pump 1-FW-P-3B-OC- 06/11/2020.
2A
204212217 Open/Inspect/Overhaul (RCE CA7783062) (R/R) 4/24/2020
204213442 Open/Inspect Check Valve (RCE CA7783062) (R/R) 03/12/2020
204216386 PM: Open/Insect Check Valve 04/20/2020.
204218301 84 Day Frequency. PT: Mtr Driven Aux FW Pump 1-FW-P- 10/28/2020.
3B- OC-22A
204225060 PM: Open/Inspect Check Valve, 01-SW--773-CKVALV
204225062 Work Order 38204225062, PM: Open/Inspect Check Valve,
01-SW--778-CKVALV
204228026 PM: Valve Replacement, 01-CH--76-CLVALV
204228027 PM: Valve Replacement, 01-CH--92-CKVALV
204228029 OM: Valve Replacement, 01-CH--116-CKVALV
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