ML23041A023
| ML23041A023 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 02/13/2023 |
| From: | Matthew Fannon NRC/RGN-II |
| To: | Stoddard D Dominion Energy Co |
| References | |
| EA-22-084 IR 2022004 | |
| Download: ML23041A023 (30) | |
See also: IR 05000280/2022004
Text
Daniel G. Stoddard
Senior Vice President
and Chief Nuclear Officer
Dominion Energy
Innsbrook Technical Center
5000 Dominion Boulevard
Glen Allen, VA 23060-6711
SUBJECT: SURRY POWER STATION - INTEGRATED INSPECTION REPORT
05000280/2022004 AND 05000281/2022004
Dear Daniel Stoddard:
On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at Surry Power Station. On January 19, 2023, the NRC inspectors discussed the
results of this inspection with James Shell, Director, Nuclear Station Safety and Licensing, and
other members of your staff. The results of this inspection are documented in the enclosed
report.
Three findings of very low safety significance (Green) are documented in this report. Three of
these findings involved violations of NRC requirements. We are treating these violations as non-
cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
Licensee-identified violations which were determined to be of very low safety significance and
Severity Level IV are documented in this report. We are treating these violations as non-cited
violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations 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.February 13, 2023
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,
Matthew S. Fannon, 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
Signed by Fannon, Matthew
on 02/13/23
x SUNSI Review x Non-Sensitive x Publicly Available
Sensitive Non-Publicly Available
OFFICE RII: DRP RII: DRP RII: DRP
NAME J. Seat S. Kennedy M. Fannon
DATE 02/10/2023 02/10/2023 02/13/2023
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers: 05000280 and 05000281
License Numbers: DPR-32 and DPR-37
Report Numbers: 05000280/2022004 and 05000281/2022004
Enterprise Identifier: I-2022-004-0023
Licensee: Virginia Electric and Power Company
Facility: Surry Power Station
Location: Surry, VA
Inspection Dates: October 01, 2022, to December 31, 2022
Inspectors: S. Kennedy, Senior Resident Inspector
E. Bousquet, Resident Inspector
J. Diaz-Velez, Senior Health Physicist
S. Downey, Senior Reactor Inspector
B. Kellner, Senior Health Physicist
J. Reed, Health Physicist
J. Rivera, Health Physicist
A. Rosebrook, Senior Reactor Analyst
M. Schwieg, Senior Reactor Inspector
B. Towne, Senior Resident Inspector
A. Wilson, Senior Project Engineer
Approved By: Matthew S. Fannon, 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. A licensee-identified
non-cited violation is documented in report section: 71153.
List of Findings and Violations
Transient Combustible Stored in a Restricted Area
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [P.5] - 71111.05
Systems NCV 05000280/2022004-01 Operating
Open/Closed Experience
An NRC identified finding of very-low safety significance (Green) and an associated Non-Cited
Violation (NCV) of License Condition 3.I, "Fire Protection," associated with the licensee's
failure to implement and maintain in effect, the provisions of the approved fire protection
program as described in the Updated Final Safety Analysis Report (UFSAR), which resulted in
storage of a transient combustible within a restricted or combustion free zone.
Failure to Manage Risk During "C" Reserve Station Service Transformer Maintenance
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.13] - 71111.13
Systems NCV 05000280,05000281/2022004-02 Consistent
Open/Closed Process
An NRC-identified finding of very low safety significance (Green) and an associated Non-Cited
Violation of 10CFR50.65(a)(4), "Requirements for monitoring the effectiveness of
maintenance at nuclear power plants, was identified for the failure of the licensee to manage
the increase in risk during C reserve station service transformer (RSST) maintenance.
Specifically, the licensee did not include the emergency diesel generator (EDG) output
breakers in the protected equipment boundary for the C RSST work activity, which resulted
in the EDGs not being fully protected.
Inadequate Cause Evaluation for #1 EDG Failure
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [P.2] - 71153
Systems NCV 05000281,05000280/2022004-03 Evaluation
Open/Closed
An NRC identified finding of very low safety significance (Green) and an associated Non-Cited
Violation (NCV) of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and
Drawings, for the failure to implement licensee procedure PI-AA-300, Cause Evaluation.
Specifically, during the extent of condition review, the licensee did not identify that safety-
related motors are similar objects that could be affected by the same cause of the #1
emergency diesel generator failure which occurred on July 18, 2022, and bounded the
condition to only the stations diesel generators.
2
Appendix R Cable Separation Non-Compliance
Cornerstone Severity Cross-Cutting Report
Aspect Section
Not Applicable Severity Level IV Not Applicable 71153
NCV 05000280,05000281/2022004-04
Open/Closed
The licensee identified a non-compliance with the regulatory criteria set forth in 10 CFR 50,
Appendix R,Section III.G. Specifically, control power cables associated with emergency
diesel generation output breakers and emergency bus feeder breakers were identified to not
meet the requirements of 10 CFR 50, Appendix G, Section III.G 2, following review of Fleet
Operating Experience at the North Anna Power Station. There was no performance deficiency
identified as the condition had been addressed in the Appendix R compliance report using the
circuit analysis available at the time.
Additional Tracking Items
Type Issue Number Title Report Section Status
URI 05000280,05000281/20 Appendix R Cable 71153 Closed
22003-03 Separation
LER 05000280,05000281/20 LER 2022-001-00 for Surry 71153 Closed
22-001-00 Power Station, Unit 1 and
Unit 2, Failure of Two Intake
Canal Level Probes Due to
LER 05000280,05000281/20 LER 2022-002-00 for Surry 71153 Closed
22-002-00 Power Station, Units 1 and
2, Failure of Unit 1
Results in an Operation or
Condition Prohibited by
Technical Specifications
3
PLANT STATUS
Unit 1 began the inspection period at or near rated thermal power (RTP). On October 30, the
unit was shut down for a planned refueling outage. The unit was returned to RTP on December
19 and remained at or near RTP for the remainder of the inspection period.
Unit 2 operated at or near RTP for the entire inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors performed activities described in IMC 2515,
Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of
IPs. The inspectors reviewed selected procedures and records, observed activities, and
interviewed personnel to assess licensee performance and compliance with Commission rules
and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) Alternate AC diesel during the # 2 EDG out of service for monthly performance test
on October 17, 2022
(2) Unit 1 safety systems (low head safety injection, inside recirculation spray, outside
recirculation spray, containment spray, and auxiliary feedwater) during transition from
hot shutdown to cold shutdown on October 30, 2022
(3) Spent fuel pit cooling following Unit 1 core offload for refueling on November 11, 2022
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated system configurations during a complete walkdown of the
residual heat removal system in the shutdown cooling mode of operation on
November 1, 2022.
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:
4
(1) Fire pump house, fire areas 32A and 32B, on October 6, 2022
(2) Emergency diesel generator room 1, fire area 6, on October 14, 2022
(3) Unit 1 cable vaults and tunnels, fire zone 1, on October 21, 2022
(4) Unit 1 containment, fire area 15, on November 3, 2022
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) Mechanical equipment room 5 on November 17, 2022
71111.08P - Inservice Inspection (ISI) Activities (PWR)
PWR Inservice Inspection Activities Sample (IP Section 03.01) (1 Sample)
(1) The inspectors reviewed the following In-service activities from November 14, 2022 to
November 21, 2022:
03.01.a - Nondestructive Examination and Welding Activities
Ultrasonic examinations on vessel shell welds
Visual examinations of the core barrel and thermal shield
Visual examinations for reactor coolant system (RCS) leakage (VT-2)
Liquid penetrant examination for 10 residual heat removal system (RHR)
piping and valve 1-RH-20
Welding activities on new 10 RHR piping and valve 1-RH-20
03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities
Boric acid program corrective action reports
03.01.d - Pressurized-Water Reactor Steam Generator (SG) Tube Examination
Activities
SG 1A - R1C86
SG 1B - R45C48, R40C51
SG 1C - R39C23
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
(1) The licensee completed the annual requalification operating examinations required to
be administered to all licensed operators in accordance with Title 10 of the Code of
Federal Regulations 55.59(a)(2), "Requalification Requirements," of the NRC's
"Operator's Licenses." During the week of November 7, 2022, the inspector
performed an in-office review of the overall pass/fail results of the individual operating
examinations and the crew simulator operating examinations in accordance with
Inspection Procedure (IP) 71111.11, "Licensed Operator Requalification
Program." These results were compared to the thresholds established in Section
5
3.03, "Requalification Examination Results," of IP 71111.11.
The inspectors reviewed and evaluated the licensed operator examination failure
rates for the requalification annual operating exam completed on March 31, 2022.
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 main
control room during the Unit 1 shutdown for a refueling outage on October 29, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1) The inspectors observed and evaluated licensed operator requalification training
involving a scenario which included a reactor coolant system leak from the residual
heat removal system suction, followed by a loss of all AC power on October 18, 2022.
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) 1-EP-BKR-14J4, 1-RS-P-1B inside recirculation spray pump breaker, failed to close
during logic test on November 1, 2022.
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) Unit 1 auxiliary feedwater full-flow recirculation piping excavation extent of condition
evaluation as a result of Unit 2 auxiliary feedwater full-flow recirculation line leaks on
December 2, 2022.
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) Emergent risk assessment on Units 1 and 2 during "B" main control room chiller
inoperable on October 20, 2022
(2) Unit 1 shutdown risk plan review in preparation for 1R31 outage on October 31, 2022
6
(3) Risk mitigation actions for Unit 1 residual heat removal system following entry into
cold shutdown on November 1, 2022
(4) Risk mitigation actions for U1 electrical configuration with "C" reserve service station
transformer in backfeed on November 3, 2022.
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1) Condition report (CR) 1210757, "B" main control room chiller (1-VS-E-4B) thermal
expansion valves found non-responsive resulting in 1-VS-E-4B being declared
inoperable on October 19, 2022
(2) CR1211518, N-32 (Unit 1 source range nuclear instrument channel 2) declared
inoperable on October 29, 2022
(3) CR1212472, Unit 1 charging pump suction valves (1-CH-MOV-1115B/D) found
closed, affecting cross-tie availability on November 10, 2022
(4) CR1213925, Unit 2 computer enhanced rod position indication system inoperable on
November 28, 2022
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1
Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1) Design equivalent change package SU-22-00161 for 1-SI-TV-101B, Unit 1
accumulator vent outside trip valve, seat modification
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (9 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system
operability and/or functionality:
(1) 1-OSP-SI-012, Leakage Test of Low Head Safety Injection (LHSI) Suction MOV for
post maintenance testing of 1-SI-MOV-1826B (LHSI pump "B" suction from refueling
water storage tank) on October 12, 2022
(2) 1-OPT-SI-005, LHSI Pump Test to satisfy post-maintenance test for return to service
of 1-SI-P-1B following maintenance on October 12, 2022
(3) 2-OPT-CH-005, Boric Acid Transfer Pumps Operability and Performance Test for
post maintenance testing of 2D boric acid transfer pump on October 31, 2022
(4) Return to service testing of N32 source range nuclear instrument following
replacement on November 3, 2022 (Work Order 38204304661)
(5) 0-ECM-0102-02, Stationary Battery Intercell Connections Cleaning and Lubrication,
following maintenance to address high resistance readings between cells 28 and 29
of the 1B station battery, on November 15, 2022
7
(6) 1-OSP-FW-001, Auxiliary Feedwater Turbine Overspeed Trip Test, following
inspection of overspeed trip device on December 2, 2022
(7) 0-ECM-0103-02, Electrical Corrective Maintenance, following maintenance on the 1B-
1 battery charger panel on December 2, 2022
(8) 1-OPT-CT-206, Leak Test of 1-RS-E-1D Service Water Side, following weld repair on
D recirculation spray heat exchanger service water discharge piping on December 6,
2022
(9) 0-OPT-ZZ-008, American Society of Mechanical engineers (ASME) System Pressure
Tests, following weld repair of the Unit 1 charging pump intermediate seal cooler on
December 7, 2022
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated Unit 1 refueling outage 1R31 activities from October 30,
2022, to December 13, 2022.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability
and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (2 Samples)
(1) 0-EPT-0104-01, Semi-annual Station Battery Test, on October 19, 2022
(2) 2-OPT-FW-003/007, Turbine-driven Auxiliary Feedwater (AFW) Pump 2-FW-P-
2/Turbine Driven AFW Pump Steam Supply Line Check Valve Test, on October 25,
2022
RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)
(1) 1-OPT-RC-10.1, Reactor Coolant Leakage Walkdown at Cold Shutdown, on
November 1, 2022
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
(1) 1-OPT-CT-201, Containment Isolation Valve Local Leak Rate Testing (Type C
Containment Testing) on December 12, 2022
FLEX Testing (IP Section 03.02) (1 Sample)
(1) 0-MPM-1960-01, Semi-Annual or Annual Test of Beyond Design Basis (BDB) FLEX
Equipment, BDB Auxiliary Feedwater Pump 2B on November 3, 2022
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
8
(1) The inspectors evaluated how the licensee identifies the magnitude and extent of
radiation levels and the concentrations and quantities of radioactive materials and
how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated how the licensee instructs workers on plant-related
radiological hazards and the radiation protection requirements intended to protect
workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and
controlling contamination and radioactive material:
(1) Workers exiting the radiologically controlled area (RCA) during routine operations and
Unit 1 refueling outage.
(2) Observed radiation protection (RP) staff surveying and releasing personal items
leaving the RCA
(3) Observed licensee controls for highly activated or contaminated materials (non-fuel)
stored in spent fuel pool
Radiological Hazards Control and Work Coverage (IP Section 03.04) (5 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following
radiological work:
(1) RWP 2515-1, MRP 227 ISI Inspection Phase 2 Activities
(2) RWP 2551, SLR - CAT Elimination Project Activities
(3) RWP 2516, Lower Internals Lift & Set Activities
(4) RWP 2501 "B" Loop S/G Primary Eddy Current Activities
(5) RWP 2104, Mechanical Maintenance Support Activities
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very
(1) OVHD gas surge tank room
(2) Units 1/2 volume control tank room
(3) Auxiliary building sump
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section
03.06) (1 Sample)
(1) The inspectors evaluated radiation worker and radiation protection technician
performance as it pertains to radiation protection requirements.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (2 Samples)
9
The inspectors evaluated the configuration of the following permanently installed ventilation
systems:
(1) Main control room ventilation system
(2) Safeguards area exhaust filtration system
Temporary Ventilation Systems (IP Section 03.02) (2 Samples)
The inspectors evaluated the configuration of the following temporary ventilation systems:
(1) High-efficiency particle absorbing (HEPA) Unit HV-1600-02, used on "A" Loop
11/12/2022
(2) HEPA Unit HV-1600-04, used on "B" Loop 11/12/2022
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
(1) The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
(1) The inspectors evaluated the licensees use and maintenance of self-contained
breathing apparatuses.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated licensee performance as it pertains to radioactive source
term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated how the licensee processes, stores, and uses external
dosimetry.
Special Dosimetric Situations (IP Section 03.04) (1 Sample)
The inspectors evaluated the following special dosimetric situations:
(1) Declared pregnant worker.
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (10 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant
walkdowns:
(1) Area radiation monitors in auxiliary building
(2) Portable friskers located at multiple areas within the auxiliary building
10
(3) Portable ion chambers survey instruments (RO-20) located at the instrument issue
area
(4) Portable Geiger-Muller (GM) survey instruments (Radeye G) located at the instrument
issue area
(5) Portable telescoping GM survey instruments (Telepole & Telepole II) located at the
instrument issue area
(6) Argos-5APB/Zeus personnel contamination monitors located at the RCA exit
(7) GEM-5APB portal monitors located at the primary access point exit
(8) Sirius hand and foot monitors located outside the containment step off pad and at exit
points to the yard
(9) Liquid radioactive waste radiation monitor (1-RE-131) located in the Surry radwaste
facility (initiates discharge isolation on alarm)
(10) Radwaste facility vent stack radiation monitor (RE-100/101)
Calibration and Testing Program (IP Section 03.02) (14 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection
instruments:
(1) Work Order (WO) 38204200713, Calibrate 1-RM-RMS~157 (Main Control Room Area
Radiation Monitor)
(2) WO 38204219098, Containment High Range Radiation Monitor 2-RM-RMS-228
Channel Calibration, 11/11/2021
(3) WO 38204218983, Containment High Range Radiation Monitor 2-RM-RMS-227
Channel Calibration, 11/11/2021
(4) Eberline RO-20 ion chamber dose rate instrument, serial number (S/N) 12251,
calibration dates 3/23/2021 and 5/2/2022
(5) MGP AMP-100 underwater GM tube dose rate instrument, S/N 5012-044, calibration
dates 9/28/2017 and 8/18/2022
(6) MGP Telepole GM tube dose rate instrument, S/N 6609-081, calibration dates
11/4/2021 and 7/7/2022
(7) Mirion Telepole II GM tube dose rate instrument, S/N 232920-133, calibration dates
5/11/2021 and 11/6/2021
(8) Eberline RO-20 ion chamber dose rate instrument, S/N 12074, calibration dates
7/14/2021 and 6/13/2022
(9) Thermo Radeye G GM tube dose rate instrument, S/N 30273, calibration dates
11/20/2019 and 2/24/2022
(10) Model CMP-0523-CV Portable air sampler, S/N 21059, calibration dates 8/27/2021
and 8/1/2022
(11) Argos-5PAB/Zeus personnel contamination monitor, S/N 1112-247, calibration dates
7/29/2021 and 4/19/2022
(12) Cronos 4 tool/equipment monitor, S/N 1312-346, calibration dates 4/20/2021 and
4/13/2022
(13) GEM-5 gamma portal monitor, S/N 1604-047, calibration dates 6/14/2021 and
6/27/2022
(14) Thermo Radeye GX frisker, S/N 11248, calibration dates 10/20/2020 and 10/18/2021
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:
11
(1) WO 38204220513, 1-VG-RM-131 Calibration (Vent Stack No. 2 Normal and High
Range Effluent Radiation Monitor), 10/05/2021
(2) WO 38204216269, Calibrate Unit 2 Containment Particulate and Gaseous radiation
Monitor (2-RM-RMS 259/260), 10/21/2021
(3) WO 38204202626, Calibrate Unit 1 Containment Particulate and Gaseous Radiation
Monitor (1-RM-RMS 159/160), 03/22/2021
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)
(1) Unit 1 (October 1, 2021, through September 30, 2022)
(2) Unit 2 (October 1, 2021, through September 30, 2022)
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
(1) Unit 1 (October 1, 2021, through September 30, 2022)
(2) Unit 2 (October 1, 2021, through September 30, 2022)
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
(1) Unit 1 (October 1, 2021, through September 30, 2022)
(2) Unit 2 (October 1, 2021, through September 30, 2022)
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)
(1) Unit 1 (October 1, 2021, through September 30, 2022)
(2) Unit 2 (October 1, 2021, through September 30, 2022)
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
(1) Unit 1 (October 1, 2021, through September 30, 2022)
(2) Unit 2 (October 1, 2021, through September 30, 2022)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)
(1) Unit 1 (October 1, 2021, through September 30, 2022)
(2) Unit 2 (October 1, 2021, through September 30, 2022)
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
(1) Unit 1 (October 1, 2021, through September 30, 2022)
(2) Unit 2 (October 1, 2021, through September 30, 2022)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
12
(1) June 1, 2021, through August 1, 2022
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) June 1, 2021, through August 1, 2022
71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03) (3 Samples)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1) Challenges with fire protection buried piping (CA8601602)
(2) "B" emergency service water pump reliability events (CA9178967, CA8597750,
CA8539503)
(3) Unit 2 "2B" charging pump cooling water pump discharge charge check valve did not
close (CA11050223)
71152S - Semiannual Trend Problem Identification and Resolution
Semiannual Trend Review (Section 03.02) (1 Sample)
(1) The inspectors reviewed the licensees corrective action program for potential
adverse trends in protected equipment practices that might be indicative of a more
significant safety issue.
71153 - Follow Up of Events and Notices of Enforcement Discretion
Event Report (IP Section 03.02) (2 Samples)
The inspectors evaluated the following licensee event reports (LERs):
(1) LER 0005280/0005281/2022-001-00 for Surry Units 1 and 2, Failure of Two Intake
Canal Level Probes Due to Biofouling, (ADAMS Accession No. ML22138A355). The
inspection conclusions associated with this LER are documented in this report under
Inspection Results Section 71153.
(2) LER 0005280/0005281/2022-002-00 for Surry Units 1 and 2, Failure of Unit 1
Emergency Diesel Generator Results in an Operation or Condition Prohibited by
Technical Specifications, (ADAMS Accession No. ML22263A429). The inspection
conclusions associated with this LER are documented in this report under Inspection
Results Section 71153.
Personnel Performance (IP Section 03.03) (1 Sample)
(1) The inspectors evaluated Unresolved Item (URI) 05000280,05000281/2022003-03,
Appendix R Cable Separation on November 21, 2022. The Inspectors closed the URI
to a SLIV NCV with no performance deficiency and a Licensee Identified NCV
documented in this report.
13
Notice of Enforcement Discretion (NOED) (IP Section 03.04) (1 Sample)
(1) The inspectors evaluated the licensee actions surrounding Notice of Enforcement
Discretion EA-22-073, which can be accessed at http://www.nrc.gov/reading-rm/doc-
collections/enforcement/notices/noedreactor.html, on July 27, 2022. The inspectors
completed Sections 03.04.c and 03.04.d of IP 71153. Completion of Sections 03.04.a
and 03.04.b of the IP were documented in Surry Power Station, Units 1 and 2 -
Integrated Inspection Report 05000280/2022003 and 05000281/2022003 (ADAMS
Accession No. ML22308A179). The inspection conclusions associated with this issue
are documented in this report under the Inspection Results Section 71153.
INSPECTION RESULTS
Transient Combustible Stored in a Restricted Area
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Systems Green [P.5] - 71111.05
NCV 05000280/2022004-01 Operating
Open/Closed Experience
An NRC identified finding of very-low safety significance (Green) and an associated Non- Cited
Violation (NCV) of License Condition 3.I, "Fire Protection," associated with the licensee's failure
to implement and maintain in effect, the provisions of the approved fire protection program as
described in the Updated Final Safety Analysis Report (UFSAR), which
resulted in storage of a transient combustible within a restricted or combustion free zone.
Description: On October 21, 2022, inspectors conducted a walkdown of the Unit 1 cable vault
penetration area, Fire Zone 1A, elevation 15 feet - 0 inches. The inspectors identified
unattended cleaning equipment (constructed of wood and plastic) within a few feet of the Unit 1
cable trays, which contained Appendix R safe shutdown cables.
The inspectors reviewed the transient fire loading report posted in the area for scaffold being built
for reactor coolant pump cable supports. Section 2, "Work Area Preparation and Precautions,"
was checked to observe the restrictions in fire zones listed in Attachments 8 or Attachment 9 or
obtain variance.
The inspectors reviewed CM-AA-FPA-101, Attachment 9, Revision 15, "Surry Power Station
Transient Combustible Loading Limits and Restrictions," which includes a restriction for the
Unit 1 cable vault, No transient within 10 ft. of vertical cable trays along the perimeter of cable
vault.
The inspectors determined the unattended cleaning equipment was located within a restricted
area and the station had failed to establish any variance or compensatory actions associated
with a transient combustible stored within a restricted area or combustion free zone.
In addition, the inspectors identified that the transient fire load permit was expired, with a
scheduled end date of June 30, 2022. The inspectors also noted that the fixed carbon dioxide
fire suppression system was out of service due to pre-outage activities in the area. A roving fire
watch was established with a 1-hour frequency through the area.
14
Corrective Actions: On October 21, 2022, the licensee removed the cleaning equipment from the
restricted area and entered this issue into their corrective action program.
Corrective Action References: CR1210965
Performance Assessment:
Performance Deficiency: The inspectors found that the licensees failure to implement the fire
protection program in accordance with licensee procedure CM-AA-FPA-101, which resulted in
the storage of a transient combustible within a restricted or combustion free zone, was a
performance deficiency within the licensees ability to foresee and prevent.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Protection Against External Factors attribute of the
Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to initiating events to prevent
undesirable consequences. Specifically, the transient combustible was stored within a
restricted or combustion free zone, which affected the zones function to prevent the spread of
fire near cable trays containing Appendix R Safe Shutdown cables. 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 and found this condition consistent with more than
minor Example 4.j.
Significance The inspectors assessed the significance of the finding using IMC 0609 Appendix
A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors
assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe
Shutdown SDP. This finding was determined to be of very-low safety significance (Green)
because the transient combustible would not likely cause a fire from existing sources of heat or
electrical energy and thus had a low degradation grading in accordance with IMC 0609,
Appendix F, Attachment 2.
Cross-Cutting Aspect: P.5 - Operating Experience: The organization systematically and
effectively collects, evaluates, and implements relevant internal and external operating
experience in a timely manner. The inspectors found that the licensee did not implement relevant
internal operating experience related to the NRC 2nd Quarter 2021 and 2nd Quarter
2022 Green NCVs regarding transient combustible stored in a restricted area.
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 UFSAR Section 9.10.1, Design Bases, states in
part, Compliance with these criteria is contained in the following documents Fire Protection
Program document and the associated Administrative Procedures describe the administrative
and technical controls. Licensee procedure CM-AA- FPA-101, Attachment 9, "Surry Power
Station Transient Combustible Loading Limits and Restrictions," which includes a restriction for
the Unit 1 cable vault penetration area that states, No transient combustibles within 10 ft. of
vertical cable trays along the perimeter of cable vault.
Contrary to the above, prior to October 21, 2022, the licensee failed to implement and maintain
in effect, the provisions of the approved fire protection program as described in the UFSAR,
15
resulting in noncompliance with the fire protection program document, CM-AA-FPA-
101, which describe the administrative and technical controls of transient combustibles.
Specifically, the licensee stored a transient combustible within the Unit 1 cable vault penetration
area restricted or combustion free zone.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Failure to Manage Risk During "C" Reserve Station Service Transformer Maintenance
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Systems Green [H.13] - 71111.13
NCV 05000280,05000281/2022004-02 Consistent
Open/Closed Process
An NRC-identified finding of very low safety significance (Green) and an associated Non- Cited
Violation of 10CFR50.65(a)(4), "Requirements for monitoring the effectiveness of maintenance
at nuclear power plants, was identified for the failure of the licensee to manage the increase in
risk during C reserve station service transformer (RSST) maintenance.
Specifically, the licensee did not include the emergency diesel generator (EDG) output
breakers in the protected equipment boundary for the C RSST work activity, which resulted in
the EDGs not being fully protected.
Description: On November 02, 2022, the licensee placed the C RSST out of service to perform
planned relay maintenance. The evaluated risk for this activity was an elevated green condition.
The loss of additional electrical offsite or emergency AC power sources could result in a high-risk
condition, loss of core cooling, or limiting Technical Specification (TS) action statements.
On November 04, 2022, inspectors reviewed the stations daily risk assessment, and performed
a walkdown of the posted equipment to ensure the risk management actions were properly
implemented. The inspectors noted that the #1, #2, and #3 EDG output breakers were not
protected. Upon further review, the inspectors identified that the licensee did not include the
EDG output breakers in the protected equipment boundary for the C RSST work activity.
Although the EDG rooms were listed as protected, the EDG output breakers, which are in the
emergency switchgear room in another area of the plant, were not listed as protected
equipment. The concern was that the licensee could have authorized inappropriate work in the
area.
The licensee maintains operator aids for risk significant equipment placed out of service for
maintenance. The aids contain a list of components required to be protected to mitigate the risk
of the equipment being out of service. The inspectors reviewed the operator aid for the C
RSST and noted that the diesel output breakers were not included. The inspectors concluded,
and the licensee agreed, that it was appropriate to protect the EDG output breakers while the
C RSST was out of service for maintenance.
Corrective Actions: Once the inspectors informed Operations personnel that the equipment
was not protected, Operations personnel took immediate actions to protect the EDG output
breakers in the field. The licensee also made changes to the RSST operator aid to include
the diesel output breakers in the protected equipment boundary for the C RSST. The
licensee entered this issue into the Corrective Action program.
16
Corrective Action References: CR1212022
Performance Assessment:
Performance Deficiency: The licensee failed to assess and manage the risk, in accordance with
10 CFR 50.65(a)(4), that resulted from maintenance activities associated with the C RSST.
Specifically, the operator aid for the C RSST out of service did not include the EDG output
breakers in the protected equipment boundary, which resulted in the EDGs not being fully
protected. This performance deficiency was within the licensee's ability to foresee and prevent.
Screening: The inspectors determined the performance deficiency was more than minor because
it was associated with the Configuration Control attribute of the Mitigating Systems cornerstone
and adversely affected the cornerstone objective to ensure the availability, reliability, and
capability of systems that respond to initiating events to prevent undesirable consequences.
Specifically, the failure to include the EDG output breakers in the protected equipment boundary
for the "C" RSST work activity could result in inappropriate work in the area and the loss of the
EDGs for the power availability shutdown safety function. 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 and found this condition consistent with more than minor
example 8.f.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix K,
Maintenance Risk Assessment and Risk Management SDP. A regional Senior Reactor Analyst
calculated incremental core damage probability (ICDP) for the maintenance using SAPHIRE 8,
Version 8.2.6, and the Surry Unit 1 SPAR Model, Version 8.80, dated May 26, 2022. An exposure
period of three days was used. Because the performance deficiency was related to inadequate
risk management actions (RMAs), the inspectors were directed to IMC 0609, Appendix K,
Flowchart 2, Assessment of RMAs. The inspectors determined the finding screened to very low
safety significance (Green) since ICDP was less than 1E-6.
Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic
approach to make decisions. Risk insights are incorporated as appropriate. The inspectors found
that the licensee used an informal operator aid to provide guidance when executing the protected
equipment procedure. The operator aid was not part of a procedure and did not have the benefits
of being vetted, reviewed, or revision controlled, and as such, was subject
to potential error.
Enforcement:
Violation: 10 CFR 50.65(a)(4), "Requirements for monitoring the effectiveness of maintenance at
nuclear power plants," states, in part, that before performing maintenance activities (including
but not limited to surveillance, post-maintenance testing, and corrective and preventive
maintenance), the licensee shall assess and manage the increase in risk that may result from the
proposed maintenance activities.
Contrary to the above, between November 2, 2022, and November 4, 2022, the licensee failed to
manage the increase in risk during the C RSST maintenance. Specifically, the licensee did
17
not include the EDG output breakers in the protected equipment boundary for the C RSST
work activity, which resulted in the EDGs not being fully protected.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Inadequate Cause Evaluation for #1 EDG Failure
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Systems Green [P.2] - 71153
NCV 05000281,05000280/2022004-03 Evaluation
Open/Closed
An NRC identified finding of very low safety significance (Green) and an associated Non- Cited
Violation (NCV) of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and
Drawings, for the failure to implement licensee procedure PI-AA-300, Cause Evaluation.
Specifically, during the extent of condition review, the licensee did not identify that safety-
related motors are similar objects that could be affected by the same cause of the #1
emergency diesel generator failure which occurred on July 18, 2022, and bounded the
condition to only the stations diesel generators.
Description: The licensee documented their evaluation of the #1 EDG loss of load event, which
occurred during monthly testing on July 18, 2022, in CR1203764. The licensees Condition
Report Review Team screened the CR as Significance Level 2 and assigned a corrective
action (CA11222927) to complete a Level of Effort Evaluation (LEE) for the issue. Following
the completion of the LEE, the licensee submitted a licensee event report (LER) in accordance
with Title 10 of the Code of Federal Regulations (10 CFR) 50.73, Licensee Event Report
Systems.
The inspectors reviewed the LER, the LEE, and other relevant documents associated with this
issue. The Level of Effort Evaluation for this issue determined that the cause of the #1 EDG
failure was corrosion between the lugs of the field leads at the bolted connection, which
connected the aluminum conductor from the power supply panel to the copper conductor on the
generator field. The aluminum conductor failed at the bolted connection due to the buildup of
corrosion, heating, and subsequent long-term degradation. The failed bolted connection
resulting in a ground on one of the poles on the generator rotor. The LEE stated that the most
likely cause of the corrosion was the connection made in 2001 when the generator was
disconnected to resolve vibration issues. Following the failure of the #1 EDG on July 18, 2022,
the licensee replaced the aluminum conductor with a copper conductor on the #1 EDG and
scheduled inspections of the generator field leads for the other EDGs and the station blackout
diesel generator.
Since the LEE did not provide an explanation for the cause of the corrosion, the inspectors
conducted a review to understand potential causes. The inspectors noted that DNES-VA-
EEN-0002, Design Standard for Cable, states the disadvantages of using aluminum
conductors include corrosion and expansion and contraction causing loose connections. The
inspectors concluded that potential causes of the corrosion were the use of the aluminum
conductors and/or a loose connection due to thermal expansion and contraction of dissimilar
metals at the copper-aluminum generator lead bolted connection.
18
The licensee performed an extent of condition review of the #1 EDG failure and determined
that there are no similar objects and other applications applicable to the identified failure.
Thus, the licensee bounded the extent of condition to the site EDGs and the station blackout
diesel generator. However, the inspectors determined that the safety-related motors in other
applications are subject to the same condition or failure mechanism observed with the #1 EDG
due to design similarities between motors and generators. The inspectors concluded
that the licensee did not implement PI-AA-300, Cause Evaluation, which states, The purpose of
an extent of condition evaluation is to perform a risk assessment of additional objects that may
have the potential for pending, and as yet, unrevealed failures.
Corrective Actions: The licensee entered this issue into their corrective action program and
intends to include motor leads in the extent of condition review for the #1 EDG failure LEE.
Corrective Action References: CR1217613
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to implement the
corrective action program in accordance with licensee procedure PI-AA-300, which resulted in
a less than adequate cause evaluation, was a performance deficiency within the licensees
ability to foresee and prevent.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Equipment 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. Specifically, the failure to perform an adequate extent of condition review could
result in the failure to identify similar equipment subject to the same condition.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix
A, The Significance Determination Process (SDP) for Findings At-Power. This finding was
determined to be of very low safety significance (Green) because the finding was a design or
qualification deficiency confirmed not to result in loss of operability.
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. The inspectors found that the licensee did not thoroughly evaluate similar
objects that could be subject to the same condition as the #1 EDG failure.
Enforcement:
Violation: 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings,
states, in part, that activities affecting quality shall be accomplished in accordance with these
instructions, procedures, or drawings. Procedure PI-AA-300, Extent of Condition Evaluation,
requires that an extent of condition evaluation to be performed as a risk assessment of
additional objects that may have the potential for pending, and as yet, unrevealed failures.
19
Contrary to the above, the licensees extent of condition evaluation for the #1 EDG failure,
which was completed on August 17, 2022, did not identify all safety-related objects that may
be subject to the same failure mechanism. Specifically, the licensee did not identify that
safety-related motors are similar objects that could be affected by the same cause of the #1
EDG failure which occurred on July 18, 2022, and bounded the condition to the stations
diesel generators.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
The disposition of this violation closes LER 05000280,05000281/2022-002-00.
Appendix R Cable Separation Non-Compliance
Cornerstone Severity Cross-Cutting Report
Aspect Section
Not Applicable Severity Level IV Not 71153
NCV 05000280,05000281/2022004-04 Applicable
Open/Closed
The licensee identified a non-compliance with the regulatory criteria set forth in 10 CFR 50,
Appendix R,Section III.G. Specifically control power cables associated with emergency diesel
generation output breakers and emergency bus feeder breakers were identified to not meet the
requirements of 10 CFR 50, Appendix G, Section III.G 2, following review of Fleet Operating
Experience at the North Anna Power Station. There was no performance deficiency identified
as the condition had been addressed in the Appendix R compliance
report using the circuit analysis available at the time.
Description: On September 13, 2021, at 1822 EDT, an apparent non-compliance with 10 CFR 50, Appendix R, Section III.G.2 (separation of redundant fire safe shutdown equipment) was
identified based on Operating Experience (OE) from North Anna Power Station (LER 2021-
002-00). A review of the affected control circuits for the Unit 1 and Unit 2 EDG output breakers
and emergency bus feeder breakers identified a concern that damage to the control power
circuits during a fire may affect the ability to provide emergency power on both units.
An 8-hour non-emergency report was made per 10 CFR 50.72(b)(3)(ii)(B) for an unanalyzed
condition (EN 55459 on 9/13/2021). Fire watches were established in the affected areas. Risk
mitigating actions have been developed, implemented, and will continue to be performed until
appropriate permanent corrective actions are in place to mitigate this condition. Licensee Event
Reports 50-280/2021-001-00 and 50-281/2021-001-00, Unanalyzed Condition Due to
Appendix R Concern Identified with Cable Separation, were submitted on November 11, 2021.
Specifically, it was determined that some EDG cables may be susceptible to a hot
short/spurious operation to the closure circuit. A spurious closure of the emergency bus normal
supply breakers after the EDG is powering the bus could result in non-synchronous paralleling,
EDG overloading, or EDG output breaker tripping due to faulted power cable from normal
supply breaker. The spurious closure of the normal supply breakers is not currently addressed
in the Appendix R Report or previous Multiple Spurious Operations (MSO) analysis.
This condition is associated with the Appendix R safe-shutdown function of the emergency
20
power system. The emergency power system is considered operable but not fully qualified for its
safety-related design function.
The following fire areas are impacted:
1) Fire Area 13, Unit 1 normal switchgear room
2) Fire Area 46, Unit 1 cable tray room
3) Fire Area 3, Unit 1 emergency switchgear and relay room
4) Fire Area 2, Unit 2 cable vault and tunnel
The circuit analysis performed by Jenson Hughes in 2021 identified previously unrecognized fire
effects which were contrary to the circuit analysis performed in the 1980s to support the
Appendix R report and in the 2010 circuit analysis to support the MSO calculations. There is no
performance deficiency associated with this due to Appendix R, Table 9-2, Note 6, which was
reviewed and accepted by the NRC, thus it was reasonable for the licensee to believe they
were in compliance with Appendix R. The further circuit analysis was a voluntary effort
conducted by the licensee.
Note 6 in the Appendix R report, Table 9-2, which is referenced multiple times in the MSO
calculations and used as a basis for why III.G2 separation is not required states:
The offsite power supply circuit breakers (15H8, 15J8, 25H8, 25J8) must be opened to permit
the onsite (EDG) power supply circuit breakers (15H3, 15J3, 25H3, 25J3) to be closed.
Based on evaluation of the elementary diagrams, the offsite supply circuit breaker can be
opened, if the cable noted, is opened or shorted due to fire damage. Therefore, the fire will not
prevent use of the power supply.
Corrective Actions: The licensee identified this concern through their operating experience
program, immediately implemented appropriate compensatory actions as directed by their fire
protection program, entered the concern into the corrective action program, conducted an
evaluation and extent of condition review, and develop long term corrective actions to restore
compliance with Appendix R.
Corrective Action References: CR 1180502, CR 1197760
Performance Assessment: The NRC determined this violation was not reasonably foreseeable
and preventable by the licensee and therefore is not a performance deficiency. Since the
adverse condition has to do with fire protection, there are no examples in NRC Enforcement
Policy, Section 6.0, which would be applicable to this condition. As a result, a detailed risk
analysis using the guidance in IMC 0609 Appendix F, Fire Protection Significance
Determination Process, was performed to characterize risk. A regional SRA modelled each
affected fire event tree in the affected fire areas, using SAPHIRE 8, Version 8.2.6, and the
Surry Unit 1 SPAR Model, Version 8.80, dated 5/26/2022. The SPAR models fire initiating
event (IE) frequencies were developed using data from the Surry Individual Plant Evaluation of
External Events (IPEEE) report. The SRA adjusted each event tree to account for spurious
operations of effected breakers and the failure of 25H8 to open in certain fire scenarios.
The original bounding risk assessment was then revised to account for the non-conforming
condition. For each fire area the applicable sequences were reviewed to determine if 1) the event
21
initiated as a loss of off-site power (LOOP) and 2) If a LOOP is possible (IE can the emergency
bus and/or transfer bus be restored.) For sequences which were initiated by a LOOP, the
spurious opening of breakers 15H8, 15J8, 25H8, and 25J8 were removed from the bounding
case.
Based upon plant walkdowns, some fire sequences were eliminated, and some IE frequencies
were adjusted to remove overly conservative assumptions. The contribution from spurious
operation or 25H8 failing to open was 8.65E-7. This would correspond to a finding of very low
safety significance and therefore was characterized as a SLIV finding in the traditional
enforcement process.
This evaluation remains very conservative since the it is assumed that the hot short was not
cleared when the associated buses were deenergized and that spurious operations would occur
immediately upon restoration. Additionally, the 25H8 vulnerability is conservatively assumed to
be exploited for every fire scenario in Fire Area 1 (Unit 1 emergency switchgear
room).
Enforcement:
Violation: Surry Operating License Condition 2.D for Units 1 and 2 requires, in part, that 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 (UFSAR). Section 9.5.1.1 of
the UFSAR states, in part, that the Surry Power Station satisfies the regulatory criteria set forth
in 10 CFR 50, Appendix R, Section III.G. Contrary to the above, from the 1980s until discovery
on September 21, 2021, Surry Units 1 and 2 did not meet the requirements of 10 CFR 50,
Appendix R, Section G.2, due to inadequate separation of control power cables associated with
the emergency switchgear supply breakers.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
The disposition of this violation closes URI: 05000280,05000281/2022003-03.
Licensee-Identified Non-Cited Violation 71153
This violation of very low safety significance was identified by the licensee and has been entered
into the licensee corrective action program and is being treated as a non-cited violation,
consistent with Section 2.3.2 of the Enforcement Policy.
Violation: The licensee performed calculations SU-ETE-000-ETE-SU-2011-0051, Appendix R
Multiple Spurious Operation (MSO) Evaluation - Surry Units 1 and 2, Revs 0,1, and 2, and SU-
ETE-000-ETE-SEP-2011-012, Appendix R Multiple Spurious Operations (MSO) Identification -
Surry Rev 0, 1, 2, and 3; using NEI-00-01, Rev 2. The Circuit Analysis of Record for these
calculations was SAIC/Tri-En Corporation Circuit Analysis Files dated 12/22/2010. Calculation
SU-ETE-000-ETE_SEP-2011-12 considered the 54 MSO scenarios listed in NEI 00-01, Rev 2,
Table G-2, PWR Generic MSO list including MSO scenarios 47(MSO resulting in a EDG
Overload) and 49 (MSO resulting in an out of phase synchronization [OOPS] event). Both were
flagged for further review. Circuit analysis was performed, and the question of EDG control
power cables had previously been addressed via 1984 modification and room specific fire safe
shutdown procedure. Both Scenarios 47 and 49 were specifically reviewed and considered
22
resolved to an acceptable level of risk by the current procedures. Scenario 49 was evaluated in
calculation SU-ETE-000-ETE-2011-0051 assuming the EDG was damaged due to the EDG
Output breaker spuriously closing onto the energized bus, it was assumed for this scenario that
offsite power remains in service. An interlock prevents the EDG output breaker from closing until
after the normal supply breaker has been opened for
2.2 seconds. Thus, it was not expected to occur. This assumption is allowed per NEI-00-01,
Rev. 2, Table 2. However, the calculation did not address an OOPS event due to spurious
closure of the normal feeder break due to a hot short after the EDG was loaded and providing
power to the associated bus. NEI-00-01, Rev 2, required each scenario be evaluated
independently. Thus, Scenario 49 was not fully evaluated. Failure to fully evaluate Scenario 49
was a performance deficiency. This OOPS Scenario can only occur if offsite power remains
available behind the normal feeder breaker (i.e., the transfer buses are energized or can be
restored).A detailed risk analysis using the guidance in IMC 0609 Appendix F, Fire Protection
Significance Determination Process, was performed to characterize risk. A regional SRA
modelled each affected fire event tree in the affected fire areas using SAPHIRE 8, Version
8.2.6, and the Surry Unit 1 SPAR Model, Version 8.80, dated 5/26/2022. The SPAR Models fire
initiating event frequencies were developed using data from the Surry IPEEE report. The SRA
adjusted each event tree to account for spurious operations of effected breakers and the
potential for a significant OOPS event. Based upon plant walkdowns some fire sequences were
eliminated, and some IE frequencies were adjusted to remove overly conservative
assumptions. The risk contribution from OOPS events was bounded at 9.4E-7, with the
dominant accident sequence being a fire in the normal switchgear room with an OOPS event
on the 1J Bus due to spurious operation of the 15J8 breaker, due to a fire damage following
restoration of the D and E transfer buses.
This evaluation remains very conservative since the it is assumed that the hot short was not
cleared when the associated buses were deenergized and that spurious operations would occur
immediately upon restoration.
Significance/Severity: Green.
Corrective Action References: CR 1180502, CR 1197760
23
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On January 19, 2023, the inspectors presented the integrated inspection results to
James Shell, Director, Nuclear Station Safety and Licensing, and other members of the
licensee staff.
On November 21, 2022, the inspectors presented the Unit 1 ISI and SG inspection
results to Fred Mladen, Site Vice President, and other members of the licensee staff.
On November 21, 2022, the inspectors presented the radiation protection inspection
results to Fred Mladen, Site Vice President, and other members of the licensee staff.
24
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.04 Procedures 0-OP-AAC-001A AAC Diesel Generator Systems Alignment Revision 14
0-OP-FC-001A Spent Fuel Pit Cooling System Alignment Revision 7
1-GOP-2.8 Unit Cooldown, HSD to CSD for Refueling Revision 43
71111.06 Corrective Action CR1212062 Flood Control Testing / Probe Failure 11/04/2022
Documents
Corrective Action CR1213230 1-CW-LS-107C1 Non Functional as Reported in 11/17/2022
Documents CR1212062
Resulting from
Inspection
Engineering Internal Flooding Analysis Supplemental Report 11/26/1991
Evaluations
Procedures 0-AP-13.00 Turbine Building or MER 3 Flooding Rev. 33
Work Orders WO#38204195198 Inspect 96" CW Expansion Joint 03/08/2021
WO#38204210035 Turbine Building Flood Control Testing 11/05/2022
71111.08P Corrective Action CR1175477 Boric Acid leak from valve 1-CH-ICV-3609 06/20/2021
Documents CR1212700 Deformation of thermal shield support block 11/12/2022
CR1212743 Unit 1 MRP-227 Recordable Indication Thermal Shield 11/12/2022
Flexure 270 Degrees
CR1212744 Unit 1 MRP-227 Recordable Indication Thermal Shield 11/12/2022
Flexure 210 Degrees
Drawings 1800123-11448 Residual Heat Removal Coolant Line Thru Heaters - Unit 1 1
Miscellaneous 2022-060 Repair/Replacment Plan RHR Inlet Pipings and Valve 1-RH- 10/31/2022
20
ETE-CEP-2021- Steam Generator Condition Monitoring and Operational 05/15/2021
1003 Assessment: Surry Unit 1 Refueling Outage EOC30 (1R30)
ETE-CEP-2022- Steam Generator Degradation Assessment: Surry Unit 1 10/26/2022
1004 Refueling Outage 1R31
ETE-CEP-2022- Steam Generator Degradation Assessment - Surry Unit 1 10/24/2022
1004 Refueling Outage 1R31 - Fall 2022
INR-S1R31-22- Surry 1R31 Remote Visual Examination Indication 11/12/2022
001 Notification report
NDE Reports Supplemental NDE Personnel Certification Review 11/10/2022
25
Inspection Type Designation Description or Title Revision or
Procedure Date
Checklists
1-OPT-RC-10.1 Visual Examination for leakage (VT-2) 10/30/2022
54-ISI-30-023 Supplemental NDE Personnel Certification Review 11/03/2022
Checklists
BOP-PT-22-089 Liquid Penetrant Examination Final Weld 1-44A 11/11/2022
BOP-PT-22-091 Liquid Penetrant Examination Final Weld 1-45A 11/11/2022
INR-S1R31-22- Surry 1R31 Remote Visual Examination Indication 11/12/2022
002 Notification report
INR-S1R31-22- Surry 1R31 Remote Visual Examination Indication 11/12/2022
003 Notification report
INR-S1R31-22- Surry 1R31 Remote Visual Examination Indication 11/12/2022
004 Notification report
Procedures 1-OPT-RC-10.1 Reactor Coolant Leakage Walkdown at Cold Shutdown 11
54-ISI-808-000 Automated Phased Array Ultrasonic Examination of Pwr 0
Vessel Shell Welds
CM-AA-NWP-101 Weld Package WO 38204291162 11/08/2022
MRP-08 Boric Acid Corrosion Guidebook 2
71111.13 Procedures SU-ADM-OP-AA- Protected Equipment Revision 5
600
SU-ADM-OP-SU- Protected Equipment Revision 8
601
SU-ADM-OU-AA- Shutdown Risk Management Revision 13
200
SU-ADM-OU-SU- Shutdown Safety Assessment Checklist Revision 16
201
71111.19 Corrective Action CR1212760 UPS 1B-1 Battery Charger Failure
Documents CR1212794 1B Battery connection has high resistance reading 11/13/2022
Work Orders WO#38103619171 PM: MAJOR BC/INV/SS CIR. BD, FUSE,ETC 11/15/2022
REPLACEMENT
WO#38204208950 Battery intercell connection inspection 11/15/2022
71124.04 Miscellaneous Surry Unit 1 Characterization of Alpha Source Term for 09/13/2022
S1C31
71124.05 Corrective Action Condition Report Numbers: CR1166098, CR1178511, Various
Documents CR1182150, CR1191421, CR1193259, CR1200419, and
26
Inspection Type Designation Description or Title Revision or
Procedure Date
CR1202502
Corrective Action CR1213060 0-HSP-INST-001, Maintenance of Instrument Calibrators, 11/16/2022
Documents requires evaluation
Resulting from CR1213307 NRC RP Inspection Observations - Procedure 0-IPM-RM-G- 11/18/2022
Inspection 002 and 1-IPT-CC-VG-RM-131 source decay data
expiration and Tl-204 source age
Work Orders WO38204227562 Calibrate N-16 Rad Monitor 07/06/2022
27