ML21120A155
| ML21120A155 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/30/2021 |
| From: | Stewart Bailey NRC/RGN-II |
| To: | Stoddard D Virginia Electric & Power Co (VEPCO) |
| References | |
| IR 2021001 | |
| Download: ML21120A155 (20) | |
See also: IR 05000280/2021001
Text
April 30, 2021
Mr. Daniel G. Stoddard
Senior Vice President and Chief Nuclear Officer
Innsbrook Technical Center
5000 Dominion Boulevard
Glen Allen, VA 23060-6711
SUBJECT: SURRY POWER STATION - INTEGRATED INSPECTION REPORT
05000280/2021001 AND 05000281/2021001
Dear Mr. Stoddard:
On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at Surry Power Station. On April 12, 2021, the NRC inspectors discussed the results of this
inspection with Mr. Doug Lawrence, Surry Site Vice President and other members of your staff.
The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding
involved a violation of NRC requirements. We are treating this violation as a non-cited violation
(NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this
inspection report, you should provide a response within 30 days of the date of this inspection
report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional
Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at
Surry Power Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,
Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC
Resident Inspector at Surry Power Station.
D. Stoddard 2
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
X Non-Sensitive X Publicly Available
X SUNSI Review
Sensitive Non-Publicly Available
OFFICE RII: DRP RII: DRP RII: DRP RII: DRP
NAME DJackson LMcKown BTowne SBailey
DATE 4/28/2021 4/28/2021 4/30/2021 4/30/2021
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers: 05000280 and 05000281
License Numbers: DPR-32 and DPR-37
Report Numbers: 05000280/2021001 and 05000281/2021001
Enterprise Identifier: I-2021-001-0076
Licensee: Virginia Electric and Power Company
Facility: Surry Power Station
Location: Surry, VA
Inspection Dates: December 07, 2020 to March 31, 2021
Inspectors: L. McKown, Senior Resident Inspector
B. Towne, Resident Inspector
B. Caballero, Senior Operations Engineer
K. Kirchbaum, Operations Engineer
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
Failure to Perform Fire Protection Program Surveillances
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [P.2] - 71111.05
Systems NCV 05000280,05000281/2021001-01 Evaluation
Open/Closed
The inspectors identified a finding of very low safety significance (Green) and an associated
non-cited violation (NCV) of License Condition 3.I, Fire Protection, concerning Dominion
Energys failure to implement and maintain in effect the provisions of the approved fire
protection program as described in the Updated Final Safety Analysis Report. Multiple
examples of tests and inspections of fire protection components were not performed in
accordance with the Technical Requirements Manual which resulted in the discovery of
adverse conditions requiring corrective maintenance on December 29, 2020.
Additional Tracking Items
None.
2
PLANT STATUS
Unit 1 operated at or near rated thermal power for the entire inspection period.
Unit 2 began the inspection period at rated thermal power. On March 3, 2021, Unit 2 reduced to
approximately 70 percent in support of planned main condenser maintenance and returned to
rated thermal power the same day. The unit remained at or near rated thermal power for the
remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors 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 Disease 2019
(COVID-19), resident inspectors were directed to begin telework and to remotely access
licensee information using available technology. During this time, the resident inspectors
performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed onsite
portions of IPs. In addition, resident and regional baseline inspections were evaluated to
determine if all or portions 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 onsite. The
inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to
the onset of seasonal cold temperatures for the following systems on
January 25, 2021:
- Fire Protection
- Emergency AC Power
- Emergency Service Water
3
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-
significant systems from impending severe weather including heavy snow, hail, and
ice on February 11, 2021.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) #1 emergency diesel generator air start system on January 4, 2021.
(2) Unit 2 'A' and 'B' high head safety injection and charging pumps during 'C' pump
restoration on January 6, 2021.
(3) Unit 2 high pressure main steam and turbine controls including electro-hydraulic
control system during spontaneous closure of #4 governor and stop valves on
January 25, 2021.
(4) Units 1 and 2 spent fuel pool cooling closed cooling water alignment on
February 17, 2021.
(5) Unit 1 normal switchgear on February 22, 2021.
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 cable spreading room on January 4, 2021.
(2) Unit 1 cable tunnel on January 19, 2021.
(3) Unit 2 high head safety injection and charging pump cubicles preceding 'A' pump
motor planned maintenance on February 1, 2021
(4) Units 1 and 2 normal switchgear room fire dampers on March 2, 2021.
Fire Brigade Drill Performance Sample (IP Section 03.02) (2 Samples)
(1) The inspectors evaluated the onsite fire brigade training and performance during an
unannounced fire drill inside of the radiologically controlled area at the Unit 2 'B'
refueling water storage tank chillers February 16, 2021.
(2) The inspectors evaluated the onsite fire brigade training and performance during an
actual vehicle fire in the owner-controlled area nearby a protected area vehicle
access point on February 22, 2021.
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections:
4
(1) Multiple roof leaks into the Unit 1 normal switchgear room around and about risk-
significant equipment including control rod drive motor-generators, reactor coolant
pump motor breakers, and condensate pump motor breakers on March 17, 2021.
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
The inspectors completed an inspection to verify the licensees ability to evaluate the
performance of their licensed operators during the conduct of examinations, to assess their
ability to properly develop and administer requalification annual operating tests and biennial
written examinations, to evaluate the performance of the control room simulator and their
testing and maintenance of the simulator, to ensure that licensed individuals satisfy the
conditions of their licenses, and to assess their effectiveness in ensuring that operator
license conditions are satisfied.
(1) Biennial Requalification Written Examinations
The inspectors evaluated the quality of the licensed operator biennial requalification
written examination administered in February and March 2020.
Annual Requalification Operating Tests
The inspectors evaluated the adequacy of the facility licensees annual requalification
operating tests.
Administration of an Annual Requalification Operating Test
The inspectors evaluated the effectiveness of the facility licensee in administering
requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility
licensee is effectively evaluating their licensed operators for mastery of training
objectives.
Requalification Examination Security
The inspectors evaluated the ability of the facility licensee to safeguard examination
material, such that the examination is not compromised.
Remedial Training and Re-examinations
The inspectors evaluated the effectiveness of remedial training conducted by the
licensee, and reviewed the adequacy of re-examinations for licensed operators who
did not pass a required requalification examination.
Operator License Conditions
The inspectors evaluated the licensees program for ensuring that licensed operators
meet the conditions of their licenses.
5
Control Room Simulator
The inspectors evaluated the adequacy of the facility licensees control room
simulator in modeling the actual plant, and for meeting the requirements contained in
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(1 Sample)
(1) The inspectors observed and evaluated licensed operator performance in the control
room during Unit 2 high pressure main steam and turbine control challenges
associated with spontaneous closure of #4 governor and stop valves on
January 25, 2021.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1) The inspectors observed and evaluated a Licensed Operator Requalification
Examination that included loss of offsite power with a failed emergency diesel
generator output breaker, followed by a small break loss of coolant accident on
February 3, 2021.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components (SSCs) remain capable of performing their intended
function:
(1) Unit 2 'A' charging pump alternate discharge valve following observation of unusual
operation on March 15, 2021.
(2) Auxiliary feedwater booster pumps following discovery of discolored oil in lubricating
reservoirs on March 10, 2021.
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) 'B' emergency service water pump intake piping aging management inspection using
an underwater drone on March 10, 2021.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the
following planned and emergent work activities to ensure configuration changes and
appropriate work controls were addressed:
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(1) Units 1 and 2 elevated risk due to lower level intake transformer 2G phase alignment
challenges on January 5, 2021.
(2) Unit 2 'B' reactor coolant system (RCS) flow loop channel #3 (2-RC-FI-2426)
troubleshooting and restoration following flow oscillations during process control
performance testing on 'B' steam generator (S/G) channel #3 (2-MS-PI-2485)
pressure sensing circuit (CR1164149) on January 20, 2021.
(3) Unit 2 high pressure main steam and turbine control challenges associated with
spontaneous closure of #4 governor and stop valves on January 25, 2021.
(4) Units 1 and 2 elevated risk due to #3 emergency diesel generator overspeed trip
testing on February 7, 2021.
(5) Units 1 and 2 elevated risk during 0-IPT-CNL-LGC-8.8 Intake Canal Level Logic
Testing on March 2, 2021.
(6) Unit 1 elevated risk following discovery #3 high pressure turbine governor valve
spring tower failure concurrent with safety injection system void verification checks
and Unit 2 reactor protection system testing on March 9, 2021.
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1) CR1163311, 'C' emergency service water pump discharge filter hold down bolt
configuration concern on January 5, 2021.
(2) CR1160271, CR1160470, and CR1163099, and CR1166724 multiple challenges to
low-pressure carbon dioxide fire suppression and fire protection 10 CFR Appendix R
barrier functionality at the Units 1 and 2 cable spreading areas and mechanical
equipment room #1 on January 7, 2021.
(3) CR1164149, Unit 2 'B' RCS flow loop channel #3 (2-RC-FI-2426) troubleshooting and
restoration following flow oscillations during process control performance testing on
'B' S/G channel #3 (2-MS-PI-2485) pressure sensing circuit on January 20, 2021.
(4) CR1164302, Unit 1 approximately 45 gallons per day leakage from the refueling
water storage tank on January 21, 2021.
(5) CR1165268, Unit 2 high head safety injection pump discharge alternate injection path
isolation valve unexpected operation and noise during surveillance testing on
February 10, 2021.
(6) CR1166329, Unit 2 'B' auxiliary feedwater booster pump contaminated oil in the pump
bearing oil bubbler on February 23, 2021.
(7) CR1168011, Unit 1 apparently degraded mounting and exposed environmental
qualification conduit junction box for turbine driven auxiliary feedwater pump steam
admission valves on March 18, 2021.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system
operability and functionality:
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(1) 2-OPT-CH-003, Unit 2 'C' charging pump post-maintenance operability and
performance test following motor stator replacement on January 6, 2021.
(2) Units 1 and 2 repair and inspection of upper cable spreading area NRC-identified
degraded fire barriers (CR1160271 & CR1160470) on January 14, 2021.
(3) Unit 2 'B' RCS flow loop channel #3 (2-RC-FI-2426) troubleshooting and restoration
following flow oscillations during process control performance testing on 'B' S/G
channel #3 (2-MS-PI-2485) pressure sensing circuit (WO 38204233907) on
January 21, 2021.
(4) Unit 2 high pressure main steam and turbine control challenges associated with
spontaneous closure of #4 governor and stop valves (WO 38204234255,
38204234257, 38204234254) on January 25, 2021.
(5) 0-OPT-EG-009, Number 3 Emergency Diesel Generator Major Maintenance
Operability Test, following preventive maintenance window on February 8, 2021.
(6) Units 1 and 2 'B' emergency service water pump performance test following
maintenance (WO 38204215273) on March 10, 2021.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01) (5 Samples)
(1) 1-OPT-EG-001, #1 emergency diesel generator monthly start exercise test on
January 4, 2021.
(2) 1-OPT-FW-002 for 3B motor driven auxiliary feedwater pump testing performed on
January 20, 2021.
(3) 0-IPT-CNL-LGC-8.8 for intake canal level logic testing performed on March 2, 2021.
(4) 0-LSP-FP-046, HVAC Fire Damper Operability inspections performed on
March 2, 2021.
(5) 0-OPT-FP-009 for diesel driven fire pump testing performed on March 26, 2021.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 03.01) (2 Samples)
(1) Unit 1 (January 1 to December 31, 2020)
(2) Unit 2 (January 1 to December 31, 2020)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 03.02)
(2 Samples)
(1) Unit 1 (January 1 to December 31, 2020)
(2) Unit 2 (January 1 to December 31, 2020)
8
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 03.03) (2 Samples)
(1) Unit 1 (January 1 to December 31, 2020)
(2) Unit 2 (January 1 to December 31, 2020)
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1) Operating Experience IN 86-14: PWR Auxiliary Feedwater Pump Turbine Control
Problems based upon known leakby at the unit 1 and 2 auxiliary feedwater turbine
driven pump (TDAFW) steam admission valves initially identified in 2020.
(2) During system walkdown on 12 December 2020, 2-CS-36, Refueling Water Storage
Tank (RWST) Cooler 2B inlet valve, was found to be leaking from the body-to-bonnet
connection. This resulted in tritium containing liquid reaching the soil and a voluntary
notification to state and local agencies.
INSPECTION RESULTS
Failure to Perform Fire Protection Program Surveillances
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [P.2] - 71111.05
Systems NCV 05000280,05000281/2021001-01 Evaluation
Open/Closed
The inspectors identified a finding of very low safety significance (Green) and an associated
non-cited violation (NCV) of License Condition 3.I, Fire Protection, concerning Dominion
Energys failure to implement and maintain in effect the provisions of the approved fire
protection program as described in the Updated Final Safety Analysis Report. Multiple
examples of tests and inspections of fire protection components were not performed in
accordance with the Technical Requirements Manual which resulted in the discovery of
adverse conditions requiring corrective maintenance on December 29, 2020.
Description: On December 29, 2020, during a walkdown of the Surry Unit 1 Upper Cable
Spreading Room (CSR), the inspectors discovered multiple indications of degraded and
missing fire protection seals at the north, exterior, wall which supports carbon dioxide
suppression system functionality. Upon assessment, and lacking technical justification for
continued functionality, the station declared Unit 1 CSR low-pressure carbon dioxide (CO2)
suppression non-functional and entered the 14-day technical requirements manual action
statement (TRMAS) 3.7.3.A.2. During evaluation of the reported conditions and in response
to further inspector concerns, licensee engineering identified several additional degraded
conditions in penetrations along the wall between the Unit 1 CSR and mechanical equipment
room #1. These conditions adversely impacted the 3-hour rating of this Appendix R concrete
block fire wall. Lacking technical justification for continued functionality, the station entered
the 7-day TRMAS 3.7.8.A.2 to restore the CSR fire barrier.
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TRM 3.7.8 assures functionality of fire protection program fire barriers including seals, doors,
and dampers. Licensee reviews found that three additional fire barriers within the scope of
TRM surveillance requirement (TSR) 3.7.8.1, located in the Unit 1 CSR and the adjacent Unit
2 CSR had been omitted from TRM fire barrier inspection surveillance procedures on
January 13, 2021. The licensee entered TRMAS 3.7.8.A.2 for multiple newly identified
degraded conditions associated with immediate inspections at these locations. TSR 3.7.8.1
verifies approximately 20 percent of fire-rated barriers and fire-rated penetration seals will be
functional by detailed inspection every 12 months and 100 percent of fire-rated barriers and
fire-rated penetration seals shall be inspected every five years. These omissions were
associated with several fire protection procedure changes occurring over two years beginning
on December 2, 2003. As the licensee evaluation continued, the inspectors observed that
although new concerns appeared to be identified in discussions with the staff and reviews of
condition reports and logs, the inspectors were unable to accurately track the expanded
scope of the review, those concerns that were truly adverse, and how all of the adverse
conditions were being corrected. Following inspector discussions with station leadership on
February 4, 2021, the licensee informed the inspectors that their assessment would be
incorporated into a programmatic level of effort evaluation (LEE), CA8354712.
During performance of a fire protection system self-assessment which immediately followed
the extent of condition assessment from CA8354712, the licensee reported nine fire dampers
were not inspected and exercised on March 1, 2021. The limited initial scope of CA8354712
failed to identify other fire protection systems, structures, and components within the scope of
TSR 3.7.8.2 which had also been omitted from their fire protection program implementing
procedures. TSR 3.7.8.2 verifies that associated fire doors and fire dampers will be functional
based upon inspection within every 18 months. Immediate surveillance of these locations
revealed exactly one damper, 01-VS-FDMP-53-DAMPER, the Service Building AC Unit 152A
Outlet Fire Damper, which did not close completely. All other locations were satisfactory.
Inspection of 01-VS-FDMP-53-DAMPER found foreign material resulting in misalignment of
the damper closure mechanism. The location was cleaned, exercised, and restored to
satisfaction. It should be noted, there are no cables or equipment important to safe shutdown
in the affected fire areas associated with 01-VS-FDMP-53-DAMPER.
Corrective Actions: A detailed licensee assessment of low-pressure CO2 suppression
capacity based upon system testing found that the cumulative effect of all discovered
degradation was within the margin of system functionality. Expedited corrective maintenance
at these locations restored Units 1 and 2 CSR 3-hour fire barrier functionality. Based upon the
expanded scope of identified missed and omitted TRM fire protection surveillances, the
licensee has established a complete review of implementation of all TRM surveillances.
Corrective Action References: CR1163099, CR1163112, CR1163563, CA8354712,
CA8369409
Performance Assessment:
Performance Deficiency: The inspectors found that Dominion Energys failure to implement
fire protection program inspection requirements specifically associated with TSR 3.7.8.1 &
3.7.8.2 was a performance deficiency reasonably within the licensees ability to foresee and
prevent.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Protection Against External Factors attribute of the
Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure
10
the availability, reliability, and capability of systems that respond to initiating events to prevent
undesirable consequences. The NRC-identified barrier degradation requiring corrective
maintenance, as well as the licensee identified degradation discovered due to the missed
TSR 3.7.8.1 and TSR 3.7.8.2 inspections are examples of adverse effects to the cornerstone
objective. The inspectors used IMC 0612, Appendix E, Examples of Minor Issues, dated
January 1, 2021, to inform answers to the more than minor screening questions finding this
condition consistent with more than minor example 4.l.
Significance: The inspectors assessed the significance of the finding using Appendix F, Fire
Protection Significance Determination Process. This finding was determined to be of very
low safety significance (Green). All degraded barriers and dampers except for 01-VS-FDMP-
53-DAMPER screened to a low degradation grading in accordance with IMC 0609 Appendix
F Attachment 2 and, therefore, their safety significance was Green. While 01-VS-FDMP-53-
DAMPER screened to high degradation this example screened to Green based upon
Qualitative Screening Questions for Individual Fire Finding Categories - Fire Containment
Question 1.4.4-C in that there were no cables or equipment important to safe shutdown in the
affected fire area.
Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to
ensure that resolutions address causes and extent of conditions commensurate with their
safety significance. Upon identification of missed fire protection seal inspections within the
scope of TRM 3.7.8, Dominion Energy failed to thoroughly evaluate other potentially omitted
fire protection program TRM 3.7.8 surveillances to ensure that resolutions addressed extent
of conditions commensurate with their impact upon the fire protection program. This was
consistent with their failure to evaluate the scope of historic fire protection procedure changes
circa 2003.
Enforcement:
Violation: License Condition 3.I, Fire Protection, 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 The UFSAR section 9.10.5, Tests
and Inspections, states in part, Tests and inspections of fire protection systems are
performed in accordance with the Technical Requirements Manual.
Contrary to the above, from December 2, 2003, until discovery on December 29, 2020,
Dominion Energy failed to implement and maintain in effect the provisions of the approved
fire protection program as described in the Updated Final Safety Analysis Report such that
multiple examples of tests and inspections of fire protection systems were not performed in
accordance with the Technical Requirements Manual.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
11
Minor Performance Deficiency 71152
Minor Performance Deficiency: During a system walkdown to investigate lowering RWST
level on December 12, 2020, 2-CS-36, RWST Cooler 2B Inlet Valve was found by the
licensee to be leaking approximately 0.04 gallons per minute (gpm) from the body-to-bonnet
connection to ground. Total Leakage was estimated to be greater than 100 gallons and tritium
concentration determined to be 4.5E07 picocuries per liter (pCi/L), requiring report in
accordance with the industry voluntary groundwater protection program and 10 CFR 50.72(b)(2)(xi) (Event Notification #55035). The inspectors determined that the licensee's
failure to implement the correct torque specification on the 2-CS-36 body-to-bonnet bolts in
accordance with vendor recommendations which led to loosening and leakage was a
performance deficiency reasonably within the licensee's ability to foresee and prevent.
Screening: The inspectors determined the performance deficiency was minor. Due to the
relatively large volume of the RWST, the leakage was not sufficient to challenge the capability
of the system. Therefore, in accordance with Inspection Manual Chapter 0612 Appendix B,
the performance deficiency could not be reasonably viewed as a precursor to a significant
event; if left uncorrected would not have led to a more significant safety concern; and did not
adversely affect a cornerstone objective.
Observation: Annual Follow-up of Operating Experience IN 86-14: PWR 71152
Auxiliary Feedwater Pump Turbine Control Problems
The inspectors performed an annual follow-up of selected issues associated with IN 86-14:
PWR Auxiliary Feedwater Pump Turbine Control Problems, based upon known leakby at the
Units 1 and 2 TDAFW steam admission valves initially identified in 2020. The inspectors
reviewed preventive maintenance records, procedures, corrective action program documents,
station logs, and condition monitoring.
During a field walkdown the inspectors observed an apparent increase in Unit 2 TDAFW
casing leakage which directs condensation from the steam leakby at the admission valves to
the main steam valve house floor drains. Inspectors discovered that this leakage had
changed from drops per minute during the previous quarter to a steady pencil stream.
IN 86-14 provides operating experience at multiple stations wherein condensed steam leakby
in TDAFW steam admission lines resulted in turbine overspeed trips and auxiliary feedwater
start failures. Surry internal operating experience captured similar events in the early 1990s.
The inspectors found that though the station was experiencing TDAFW steam admission
leakby, they had not established any additional tracking actions to periodically assess
changes in casing leakage. Upon being informed of the apparent increase in casing leakage,
the licensee performed troubleshooting to validate that the rise in condensation rate with the
steam admission lines was within the capacity of the system to mitigate and drain. The station
bypassed steam traps within the TDAFW steam admission lines and observed casing
leakage to the floor drain. Changes in casing leakage to the floor drain would indicate that the
capability of the system to capture and drain steam admission valve leaky was challenged.
The licensee did not observe any adverse indication during this troubleshooting activity
indicating that the increased leakage is within the capacity of the system to mitigate and
remove.
The inspectors found that the licensee had not established additional specific actions within
work control or corrective action programs to assess and evaluate increased leakby or
condensation within the TDAFW steam admission lines which could result from further
12
degradation of the known leakby at the steam admission valves. However, the current leakby
is within the capacity of the TDAFW casing drainage system to prevent adverse impact upon
TDAFW controls. The licensee has incorporated this observation into operator rounds
turnover and system engineering condition monitoring activities to identify any changes in
TDAFW casing drain leakage to the main steam valve house floor drains. Corrective actions
on the TDAFW steam admission valves have been scheduled for the Units 1 and 2 refueling
outages in spring and fall of 2021 as the required valve maintenance cannot be performed
online.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On April 12, 2021, the inspectors presented the integrated inspection results to Mr. Doug
Lawrence, Surry Site Vice President and other members of the licensee staff.
- On January 27, 2021, the inspectors presented the licensed operator requalification
inspection results to Mr. Doug Lawrence, Surry Site Vice President and other members
of the licensee staff.
13
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.01 Procedures OP-ZZ-021 Severe Weather Preparation 27
71111.04 Corrective Action CR1165994
Documents CR1166249
Resulting from
Inspection
Drawings 11448-MKS- Component Cooling Water to Spent Fuel Pit - Isometric 4
112AR1
11548-FM-088B Flow/Valve Operating Numbers Diagram Chemical and 49
SH-2 of 3 Volume Control System
4160 Volt System 11448-FE-1A1 33
Unit 1 & 2
Miscellaneous SDBD-SPS-EG Emergency Diesel Generator System Design Basis 21
Document
SDBD-SPS-MS Main Steam and Ancillary System Design Basis Document 20
Work Orders 38204202497
71111.05 Corrective Action CR1165866, Unannounced Fire Drill Condition Reports
Documents CR1166286,
CR1166288,
CR1166291,
CR1167188,
CR1167708,
CR1167957
Fire Plans 1-FS-FP-102 Unit 1 Cable Vault Tunnel Elevation 9 feet - 6 inch 003
1-FS-FP-127 Unit 1 Cable Spreading Room Elevation 45 feet - 3 inch 005
2-FS-FP-157 Charging Pumps - Unit 2 Auxiliary Building Elevation 13 feet 3
- 0 inches and 2 feet - 0 inches
71111.06 Corrective Action CR1167826,
Documents CR1167810,
CR1167797,
CR1167796
71111.11B Corrective Action CR1164400 NRC concern of question duplication between validation and 01/22/2021
Documents actual administered biennial written exams.
14
Inspection Type Designation Description or Title Revision or
Procedure Date
Resulting from CR1164522 NRC concern with the number of operators validating 01/25/2021
Inspection biennial written exam.
Miscellaneous 38.12A, 23.03B, 2021 Annual Operating Test JPMs 01/20/2021
99.06A, 35.11A,
88.65, 52.03B,
99.04D, 88.66,
23.02D, 26.12
C4 SE-2, SE-4, 2021 Annual Operating Test Scenarios 01/20/2021
XB-2 Biennial Written Exam 02/21/2020
XB-4 Biennial Written Exam 03/06/2020
71111.11Q Procedures 1-OP-CH-023 Boration Followed by Manual Make-up Using the Blender 012
1-OSP-TM-001 Turbine Inlet Valve Freedom Test 043
71111.12 Corrective Action CR1165268
Documents
Corrective Action CR1166329
Documents
Resulting from
Inspection
Miscellaneous 3131846 2-FW-P-4B Oil Sample Analysis 03/04/2021
PRA-SPS- Surry Maintenance Rule Ranking and Performance Criteria 5
RA.PR.2
Procedures 2-OSP-FW-002 Auxiliary Feedwater Booster Pumps 11
Work Orders 38103094695,
38103336426
71111.13 Miscellaneous PHOENIX Scheduler's Evaluation for Surry Power Station, 01/05/2021
Units 1 and 2
PHOENIX Scheduler's Evaluation for Surry Power Station, 01/20/2021
Units 1 and 2
PHOENIX Scheduler's Evaluation for Surry Power Station, 01/25/2021
Units 1 and 2
PHOENIX Scheduler's Evaluation for Surry Power Station, 02/07/2021
Units 1 and 2
PHOENIX Scheduler's Evaluation for Surry Power Station, 03/09/2021
15
Inspection Type Designation Description or Title Revision or
Procedure Date
Units 1 and 2
SPS-CR.3 Rev.35 Surry Power Station Unit 1&2 Probabilistic Risk Assessment Rev 35
Model Notebook
Work Orders Work Order ESW Pump 1B Discharge Expansion Joint: Inspect 24" 03/10/2021
- 38204198119 Expansion Joint and 3" Flange (Drone)
71111.22 Procedures 0-IPT-CNL-LGC- Intake Canal Level Logic Testing 03/02/2021
8.8
0-OPT-FP-009 Diesel Driven Fire Pump Test 03/26/2021
1-OPT-FW-002 3B Motor Driven AFW Pump Test 01/20/2021
71151 Miscellaneous Surry Units 1 and 2 Plant Process Computer Calorimetric
Power January 1, 2020 through December 31, 2020
71152 Corrective Action CR1151760,
Documents CR1157069
CR1162330
CR1166724,
CR1166839,
CR1166898,
CR1166919,
CR1166929,
CR1166932,
CR1166944,
CR1167770,
CR1167867
Corrective Action CR1163330,
Documents CR1163345,
Resulting from CR1163563,
Inspection CR1163727,
CR1163917,
CR1164214,
CR1164268
Miscellaneous Surry Updated Final Safety Analysis Report 9/30/2020
Surry Power Station Technical Requirements Manual 12/31/2020
16
Inspection Type Designation Description or Title Revision or
Procedure Date
Turbine Driven Auxiliary Feedwater Pump Troubleshooting 03/03/2021
Control Form
EN#55035 NRC Form 361 Reactor Plant Event Notification Worksheet 12/12/2020
ET-CEP-06-0018 Results of Low Pressure CO2 Leakage Test Rev. 2
Procedures 0-MCM-0402-01 ITT Industries (Grinnel) Diaphragm Valve Maintenance 35
Self-Assessments CA8263622
17