IR 05000280/2021004: Difference between revisions

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==Dear Mr. Stoddard:==
==Dear Mr. Stoddard:==
On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Surry Power Station. On January 31, 2022, the NRC inspectors discussed the results of this inspection with Johnny Henderson, Director of Safety and Licensing, and other members of your staff. The results of this inspection are documented in the enclosed report.
On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Surry Power Station. On January 31, 2022, the NRC inspectors discussed the results of this inspection with Johnny Henderson, Director of Safety and Licensing, a nd other members of your staff. The results of this inspection are documented in the enclos ed report.


One finding of very low safety significance (Green) is documented in this report. This finding did not involve a violation of NRC requirements.
One finding of very low safety si gnificance (Green) is documented in this report. This finding did not involve a violation of NRC requirements.


If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Surry Power Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
If you disagree with a cross -cutting aspect assignment or a finding not associat ed with a regulatory requirement 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 th e Regional Administrator, Region II; and the NRC Resident I nspector at Surry Power Station. This letter, its enclosure, and your response (if any) will be m ade available for public inspection and copying at http://www.nrc.gov/reading-rm /a dam s.h tm l 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,
Sincerely,
/RA/
/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
 
Stewart N. Bailey, Chief Reactor Projects Br anch 4 Division of Reactor Projects
 
Docket Nos. 05000280 and 05000281 License Nos. DPR-32 and DPR-37


===Enclosure:===
===Enclosure:===
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==Inspection Report==
==Inspection Report==
Docket Numbers: 05000280 and 05000281 License Numbers: DPR-32 and DPR-37 Report Numbers: 05000280/2021004 and 05000281/2021004 Enterprise Identifier: I-2021-004-0021 Licensee: Virginia Electric and Power Company Facility: Surry Power Station Location: Surry, VA Inspection Dates: October 1, 2021 to December 31, 2021 Inspectors: D. Bacon, Senior Operations Engineer A. Butcavage, Reactor Inspector L. McKown, Senior Resident Inspector B. Towne, Resident Inspector Approved By: Stewart N. Bailey, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
Docket Numbers: 05000280 and 05000281
 
License Numbers: DPR-32 and DPR -37
 
Report Numbers: 05000280/2021004 and 05000281/2021004
 
Enterprise Identifier: I-2021- 004-0021
 
Licensee: Virginia Electric and Power Company
 
Facility: Surry Power Station
 
Location: Surry, VA
 
Inspection Dates: October 1, 2021 to December 31, 2021
 
Inspectors: D. B a con, Senior Operations Engineer A. Butcavage, Reactor Inspector L. McKown, Senior Resident Inspector B. Towne, Resident Inspector
 
Approved By: Stewart N. Bailey, Chief Reactor Projects Br anch 4 Division of Reactor Projects
 
Enclosure


=SUMMARY=
=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.
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licens ees 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===
===List of Findings and Violations===
 
Failure to Implement Spent Fuel Pool Instrumentation Equipment Functionality Requirements Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.11] - 71111.15 Systems FIN 05000280,05000281/2021004-01 Challenge the Open/Closed Unknown The inspectors identified a finding (FIN) of very low safety significance (Green) associated with Dominion Energys failure to implement Spent Fuel Pool Instrumentation Equipment Functionality requirements established in CM -AA-BDB-102, Beyond Design Basis FLEX Equipment Unavailability Tracking, Revision 12. Specifically, Dominion Energy did not recognize the red alarm light identified on May 29, 2021 could not be due to a spurious user input battery life expiration alarm as the station previously disabled these triggers.
Failure to Implement Spent Fuel Pool Instrumentation Equipment Functionality Requirements Cornerstone           Significance                               Cross-Cutting       Report Aspect             Section Mitigating             Green                                       [H.11] -           71111.15 Systems               FIN 05000280,05000281/2021004-01           Challenge the Open/Closed                                 Unknown The inspectors identified a finding (FIN) of very low safety significance (Green) associated with Dominion Energys failure to implement Spent Fuel Pool Instrumentation Equipment Functionality requirements established in CM-AA-BDB-102, Beyond Design Basis FLEX Equipment Unavailability Tracking, Revision 12. Specifically, Dominion Energy did not recognize the red alarm light identified on May 29, 2021 could not be due to a spurious user input battery life expiration alarm as the station previously disabled these triggers.


===Additional Tracking Items===
===Additional Tracking Items===
Type       Issue Number                Title                           Report Section   Status URI         05000281/2021004-02         Assessment of the Trip Hook     71111.19         Open Latch-up of the Unit 2 Turbine Driven Auxiliary Feedwater Pump
Type Issue Num ber Title Report Section Status URI 05000281/2021004-02 Assessment of the Trip Hook 71111.19 Open Latch-up of the Unit 2 Turbine Driven Auxiliary Feedwater Pump


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


Unit 2 began the inspection period at 91 percent rated thermal power in coastdown in advance of the scheduled refueling outage shutdown performed on October 24, 2021. On December 2, 2021, Unit 2 achieved criticality following the outage returning to rated thermal power on December 5, 2021. Unit 2 operated at or near rated thermal power for the remainder of inspection period.
Unit 2 began the inspection period at 91 percent rated thermal power in coastdown in advance of the scheduled refueling outage shutdown performed on October 24, 2021. On December 2, 2021, Unit 2 achieved criticality following the outage returning to rated thermal power on Decem ber 5, 2021. Unit 2 operated at or near rated ther mal power for the remainder of inspection period.


==INSPECTION SCOPES==
==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, conducted routine reviews using IP 71152, Problem Identification and Resolution, 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.
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, conducted routine reviews using IP 71152, Problem Identification and Resolution, 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 condit ions, site procedures, and standards


==REACTOR SAFETY==
==REACTOR SAFETY==
==71111.01 - Adverse Weather Protection==
==71111.01 - Adverse Weather Protection==
===External Flooding Sample (IP Section 03.03) (1 Sample)===
===External Flooding Sample (IP Section 03.03) (1 Sample)===
: (1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding in December 2021.
: (1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding in December 2021.
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* Emergency Diesel Generators
* Emergency Diesel Generators


==71111.04 - Equipment Alignment==
==71111.04 - Equipm ent Alignment==
 
===Partial Walkdown Sample (IP Section 03.01) (3 Samples)===
===Partial Walkdown Sample (IP Section 03.01) (3 Samples)===
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
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===Complete Walkdown Sample (IP Section 03.02) (1 Sample)===
===Complete Walkdown Sample (IP Section 03.02) (1 Sample)===
: (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 residual heat removal (RHR) system in shutdown cooling alignment on November 10, 2021.
: (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 residual heat removal (RHR) system in shutdown cooling alignment on Novem ber 10, 2021.


==71111.05 - Fire Protection==
==71111.05 - Fire Protection==
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Sam ples)


===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:
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 2 mechanical equipment room #5 on October 19, 2021.
: (1) Unit 2 mechanical equipment room #5 on October 19, 2021.
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==71111.06 - Flood Protection Measures==
==71111.06 - Flood Protection Measures==
===Cable Degradation (IP Section 03.02) (1 Sample)===
===Cable Degradation (IP Section 03.02) (1 Sample)===
The inspectors evaluated cable submergence protection in:
The inspectors evaluated cable submergence protection in:
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==71111.07A - Heat Sink Performance==
==71111.07A - Heat Sink Performance==
===Annual Review (IP Section 03.01) (1 Sample)===
===Annual Review (IP Section 03.01) (1 Sample)===
The inspectors evaluated readiness and performance of:
The inspectors evaluated readiness and performance of:
: (1) Unit 1, component cooling water heat exchangers A, B, C, & D, on December 15, 2021.
: (1) Unit 1, component cooling water heat exchangers A, B, C, & D, on Decem ber 15, 2021.


===71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01) ===
===71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)===
{{IP sample|IP=IP 71111.08|count=1}}
{{IP sample|IP=IP 71111.08|count=1}}
: (1) The inspectors verified that the reactor coolant system boundary, steam generator tubes, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from11/1/21 to11/30/21:
: (1) The inspectors verified that the reactor coolant system boundary, steam generator tubes, reactor vessel internals, risk -significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from11/1/21 to11/30/21:
 
03.01.a - Nondestructive Examination and Welding Activities.
03.01.a - Nondestructive Examination and Welding Activities.
* Ultrasonic Examination (UT), Component ID: 11548-WMKS-0117A1-1 / 14-RH-101 / 1-03, Elbow to Pipe Weld, NDE Report ISl-2-UT-21-019, ASME Class 1
* Ultrasonic Exam ination (UT), Com ponent ID: 11548-WMKS-0117A1-1 / 14-RH-101 / 1- 03, Elbow to Pipe Weld, NDE Report ISl -2-UT-21- 019, ASME Class 1
* Magnetic Particle Examination (MT), Component ID: 11548-WMKS-0103A2-1
* Magnetic Particle Exam ination (MT), Com ponent ID: 11548-WMKS-0103A2-1
                  / 30-SHP-122 / H0, ASME Class 2
/ 30-SHP-122 / H0, ASME Class 2
* UT Examination, CRD-48, CRD-55, and CRD-67, ASME Section XI, BO Full Penetration Weld of Adaptor to Penetration, ASME Class 1
* UT Examination, CRD-48, CRD-55, and CRD -67, ASME Section XI, BO Full Penetration Weld of Adaptor to Penetration, ASME Class 1
* Penetrant Examination (PT), Component ID: 11548-WMKS-0117A1-1 / 14-RH-101 / H016-2, Integral Attachments, RH System, ASME Class 2
* Penetrant Examination (PT), Com ponent ID: 11548-WMKS-0117A1-1 / 14-RH-101 / H016-2, Integral Attachments, RH System, ASME Class 2
* MRP-227 Examinations of Rector Vessel Internals, Surry Unit 2 Phase 1, UT of Baffle Bolts, VT of CRDM Guide Tube Guide Cards, VT Core Barrel Upper Flange Weld, Lower Core Barrel Flange Welds, VT of Thermal Shield Support Block Cap Screws
* MRP-227 Examinations of Rector Vessel Internals, Surry Unit 2 Phase 1, UT of Baffle Bolts, VT of CRDM Guide Tube Guide Cards, VT Core Barrel Upper Flange Weld, Lower Core Barrel Flange Welds, VT of Thermal Shield Support Block Cap Screws
* ASME Section. XI, IWE, VT, Comp. ID, 11548-IWE/E1.11A, Containment Floor Slab to Metal Liner Interface Area
* ASME Section. XI, IWE, VT, Comp. ID, 11548 -IWE/E1.11A, Containment Floor Slab to Metal Liner Interface Area
* Weld No. 1-05A, WO 38204217640, Line No. 2"-RC-500-1502, 02-RC--102-VALVE, NDE Rpt. No BOP-PT-21-16
* Weld No. 1-05A, WO 38204217640, Line No. 2" -RC-500- 1502, 02-RC--102-VALVE, NDE Rpt. No BOP-PT-21-16
* Weld No. 2-20A, WO 38204235324, Descript.14"-WFPD-113-601 / 2-FW-43, Final, NDE Rpt. No BOP-MT-21-108 03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities.
* Weld No. 2-20A, WO 38204235324, Descript.14" -WFPD-113-601 / 2-FW-43, Final, NDE Rpt. No BOP-MT-21-108
* RVCH VT-2 Leakage exam IAW N-729: Sample Penetration Videos for # 14,
 
                  #16, #18 and #44. Plus RVLIS and Vent Line Penetrations 03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities.
03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities.
* RVCHVT -2 Leakage exam IAW N -729: Sam ple Penetration Videos for # 14,
#16, #18 and #44. Plus RVLIS and Vent Line Penetrations
 
03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities.
* CR-1183703, Weld Repair for Tubing, Fitting Leak, 02-CH-ICV-3642-VALV, WO 3820424851
* CR-1183703, Weld Repair for Tubing, Fitting Leak, 02-CH-ICV-3642-VALV, WO 3820424851
* CR1161992, CA8245219, Boric Acid Evaluation for 02-CS--73-VALVE, Leakage
* CR1161992, CA8245219, Boric Acid Evaluation for 02-CS--73 -VALVE, Leakage
* CR1183722, Boric Acid Evaluation IAW N-566-2, for Valve 2-RC-HCV-2557A, Valve Material, and Bolts
* CR1183722, Boric Acid Evaluation IAW N -566-2, for Valve 2-RC-HCV-2557A, Valve Material, and Bolts
* Review of Initial Containment Walkdown Inspection Results 03.01.d - Pressurized-Water Reactor Steam Generator Tube Examination Activities.
* Review of Initial Containment Walkdown Inspection Results
* Site Eddy Current Examinations on: Sg "2A" ,SG "2B", SG "2C", in accordance with Document No.: 51-9333405-000
 
* Observations SG "C" Hot Leg Row 6, Col. 48 ,
03.01.d - Pressurized-Water Reactor Steam Generator Tube Examination Activities.
* Site Eddy Current Examinations on: Sg "2A",SG "2B", SG "2C", in accordance with Document No.: 51-9333405-000
* Observations SG "C" Hot Leg Row 6, Col. 48,
* Observations SG "B" HL Row 42, Col, 40, Row 10, Col 58, Row21, Col 21.
* Observations SG "B" HL Row 42, Col, 40, Row 10, Col 58, Row21, Col 21.
* Site Secondary side visual examinations] SG "2A" '2B" "2C"
* Site Secondary side visual examinations] SG "2A" '2B" "2C"
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==71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance==
==71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance==
===Requalification Examination Results (IP Section 03.03) (1 Sample)===
===Requalification Examination Results (IP Section 03.03) (1 Sample)===
: (1) The licensee completed the requalification annual operating tests 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 December 6, 2021, the inspector performed an in-office review of the overall pass/fail results of the individual operating tests and crew simulator operating tests in accordance with Inspection Procedure (IP)
: (1) The licensee completed the requalification annual operating tests 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 December 6, 2021, the inspector performed an in-office review of the overall pass/fail results of the individual operating tests and crew simulator operating tests in accordance with Inspection Procedure (IP)
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==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance==
==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 the planned shutdown for Unit 2 fall refueling outage on October 24, 2021


Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
Licensed Operator Requalification Training/Examinations (IP Section 03.02)===
: (1) The inspectors observed and evaluated licensed operator performance in the Control Room during the planned shutdown for Unit 2 fall refueling outage on October 24, 2021 Licensed Operator Requalification Training/Examinations (IP Section 03.02) ===
{{IP sample|IP=IP 71111.11|count=1}}
{{IP sample|IP=IP 71111.11|count=1}}
: (1) The inspectors observed and evaluated operations in the simulator during an Emergency Preparation drill including a tornado in the switchyard, partial loss of all AC power, and a small break loss of coolant accident on October 14, 2021.
: (1) The inspectors observed and evaluated operations in the simulator during an Emergency Preparation drill including a tornado in the switchyard, partial loss of all AC power, and a small break loss of coolant accident on October 14, 2021.


==71111.12 - Maintenance Effectiveness==
==71111.12 - Maintenance Effectiveness==
===Aging Management (IP Section 03.03) (1 Sample)===
===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:
The inspectors evaluated the effectiveness of the aging management program for the following SSCs that did not meet their inspection or test acceptance criteria:
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==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
Risk Assessment and Management Sample (IP Section 03.01) (6 Sam ples)


===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:
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) Change in risk at Unit 2 high level intake structure due to emergent failure of hose house #15 hydrant (CR1182734) on October 14, 2021.
: (1) Change in risk at Unit 2 high level intake structure due to emergent failure of hose house #15 hydrant (CR1182734) on October 14, 2021.
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: (4) Unit 2 elevated risk due to prolonged time at lowered inventory (reactor flange) from head installation error on November 21, 2021.
: (4) Unit 2 elevated risk due to prolonged time at lowered inventory (reactor flange) from head installation error on November 21, 2021.
: (5) Unit 2 plant cooldown from Hot Shutdown to Cold Shutdown via steam generator atmospheric PORVs, due to steam leak in main steam valve house on November 29, 2021.
: (5) Unit 2 plant cooldown from Hot Shutdown to Cold Shutdown via steam generator atmospheric PORVs, due to steam leak in main steam valve house on November 29, 2021.
: (6) Elevated site risk due to Unit 2 emergency condensate storage tank auxiliary feedwater recirculation line leakage (CR1187639), on December 10, 2021.
: (6) Elevated site risk due to Unit 2 emergency condensate storage tank auxiliary feedwater recirculation line leakage (CR118763 9), on December 10, 2021.


==71111.15 - Operability Determinations and Functionality Assessments==
==71111.15 - Operability Determinations and Functionality Assessments==
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)


===Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)===
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
: (1) CR1181764, Unit 1, B charging pump motor inboard bearing darkened oil sample on October 7, 2021.
: (1) CR1181764, Unit 1, B charging pump motor inboard bearing darkened oil sample on October 7, 2021.
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==71111.18 - Plant Modifications==
==71111.18 - Plant Modifications==
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 S am p les)


Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
The inspectors evaluated the following temporary or permanent modifications:
: (1) 2-MCM-1150-01, Unit 2 Reactor Disassembly and Reassembly, Revision 45 one time only changes 1, 2, & 3 following human performance event associated with improper installation of reactor vessel head studs on November 21, 2021.
: (1) 2-MCM-1150-01, Unit 2 Reactor Disassembly and Reassembly, Revision 45 one time only changes 1, 2, & 3 following human performance event associated with improper installation of reactor vessel head studs on November 21, 2021.
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==71111.19 - Post-Maintenance Testing==
==71111.19 - Post-Maintenance Testing==
Post-Maintenance Test Sam ple (IP Section 03.01) (5 Sam ples)


===Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)===
The inspectors evaluated the following post -maintenance test activities to verify system operability and functionality:
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
: (1) Correction of deficiencies from Section XI inspection (WO38103760049) on Novem ber 12, 2021.
: (1) Correction of deficiencies from Section XI inspection (WO38103760049) on November 12, 2021.
: (2) Emergency diesel generator 2 operational performance test following outage scope maintenance and start circuit design change (DCN 04 -004 & WO38204218250), on Novem ber 5, 2021.
: (2) Emergency diesel generator 2 operational performance test following outage scope maintenance and start circuit design change (DCN 04-004 & WO38204218250), on November 5, 2021.
: (3) Repair of steam leak at Unit 2 main steam trip valve steam trap bypass valve seal weld connection (CR1186767) on November 30, 2021.
: (3) Repair of steam leak at Unit 2 main steam trip valve steam trap bypass valve seal weld connection (CR1186767) on November 30, 2021.
: (4) Operational performance test of Unit 2 turbine driven auxiliary feedwater pump following outage maintenance (WO38204219508), on December 01, 2021.
: (4) Operational performance test of Unit 2 turbine driven auxiliary feedwater pump following outage maintenance (WO38204219508), on December 01, 2021.
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==71111.20 - Refueling and Other Outage Activities==
==71111.20 - Refueling and Other Outage Activities==
===Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)===
: (1) The inspectors evaluated unit 2 refueling outage 2R30 activities from October 24 to Decem ber 2, 2021.


===Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)===
: (1) The inspectors evaluated unit 2 refueling outage 2R30 activities from October 24 to          December 2, 2021.
==71111.22 - Surveillance Testing==
==71111.22 - Surveillance Testing==
The inspectors evaluated the following surveillance tests:
The inspectors evaluated the following surveillance tests:


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: (2) 2-OPT-ZZ-001, Engineered safety features actuation with undervoltage and degraded voltage - 2H bus, on October 26, 2021
: (2) 2-OPT-ZZ-001, Engineered safety features actuation with undervoltage and degraded voltage - 2H bus, on October 26, 2021


===Inservice Testing (IP Section 03.01) (2 Samples)===
Inservice Testing (IP Section 03.01) (2 Sam ples)
: (1) 1-OPT-RS-001, Containment outside recirculation spray pump flow and leak test (38204209707) on November 9, 2021
: (1) 1-OPT-RS-001, Containment outside recirculation spray pump flow and leak test (38204209707) on November 9, 2021
: (2) 2-OPT-RC-001, 2-RC-PCV-2455C power operated relief valve stroke time testing (CR1186258) on November 24, 2021
: (2) 2-OPT-RC-001, 2-RC-PCV-2455C power operated relief valve stroke time testing (CR1186258) on November 24, 2021


===Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)===
===Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)===
: (1) Reactor Coolant Letdown Containment Penetration (Penetration 28) Type 'C' test and post test valve operability stroke (2-CH-TV-2204B), work order 382042199004 on November 12,
: (1) Reactor Coolant Letdown Containment Penetration (Penetration 28) Type 'C' test and post test valve operability stroke (2-CH-TV-2204B), work order 3820 42199004 on Novem ber 12,


==OTHER ACTIVITIES - BASELINE==
==OTHER ACTIVITIES - BASELINE==
===71151 - Performance Indicator Verification


===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===
 
{{IP sample|IP=IP 71151|count=2}}
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (2 Sam ples)
: (1) Unit 1 (October 1, 2020 - September 30, 2021)
: (1) Unit 1 (October 1, 2020 - September 30, 2021)
: (2) Unit 2 (October 1, 2020 - September 30, 2021)
: (2) Unit 2 (October 1, 2020 - September 30, 2021)


===MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)===
MS06: Emergency AC Power Systems (IP Section 02.05) (2 S am p les)
: (1) Unit 1 (October 1, 2018 - September 30, 2021)
: (1) Unit 1 (October 1, 2018 - September 30, 2021)
: (2) Unit 2 (October 1, 2018 - September 30, 2021)
: (2) Unit 2 (October 1, 2018 - September 30, 2021)
 
MS07: High Pressure Injection Systems (IP Section 02.06)===
===MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)===
{{IP sample|IP=IP 71151|count=2}}
: (1) Unit 1 (October 1, 2018 - September 30, 2021)
: (1) Unit 1 (October 1, 2018 - September 30, 2021)
: (2) Unit 2 (October 1, 2018 - September 30, 2021)
: (2) Unit 2 (October 1, 2018 - September 30, 2021)


===MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)===
===MS08: Heat Rem oval System s (IP Section 02.07) (2 Samples)===
: (1) Unit 1 (October 1, 2018 - September 30, 2021)
: (1) Unit 1 (October 1, 2018 - September 30, 2021)
: (2) Unit 2 (October 1, 2018 - September 30, 2021)
: (2) Unit 2 (October 1, 2018 - September 30, 2021)


===MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)===
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 S am p les)
: (1) Unit 1 (October 1, 2018 - September 30, 2021)
: (1) Unit 1 (October 1, 2018 - September 30, 2021)
: (2) Unit 2 (October 1, 2018 - September 30, 2021)
: (2) Unit 2 (October 1, 2018 - September 30, 2021)
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: (1) Unit 1 (October 1, 2018 - September 30, 2021)
: (1) Unit 1 (October 1, 2018 - September 30, 2021)
: (2) Unit 2 (October 1, 2018 - September 30, 2021)
: (2) Unit 2 (October 1, 2018 - September 30, 2021)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)
: (1) Unit 1 (October 1, 2020 - September 30, 2021)
: (1) Unit 1 (October 1, 2020 - September 30, 2021)
: (2) Unit 2 (October 1, 2020 - September 30, 2021)
: (2) Unit 2 (October 1, 2020 - September 30, 2021)


===BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)===
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Sam ples)
: (1) Unit 1 (October 1, 2020 - September 30, 2021)
: (1) Unit 1 (October 1, 2020 - September 30, 2021)
: (2) Unit 2 (October 1, 2020 - September 30, 2021)
: (2) Unit 2 (October 1, 2020 - September 30, 2021)


==71152 - Problem Identification and Resolution (PI&R)==
==71152 - Problem Identification and Resolution (PI&R)==
===Semiannual Trend Review (IP Section 02.02) (1 Sample)===
===Semiannual Trend Review (IP Section 02.02) (1 Sample)===
: (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in foreign material exclusion that might be indicative of a more significant safety issue.
: (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in foreign material exclusion that might be indicative of a more significant safety issue.


==INSPECTION RESULTS==
==INSPECTION RESULTS==
Failure to Implement Spent Fuel Pool Instrumentation Equipment Functionality Requirements Cornerstone           Significance                             Cross-Cutting     Report Aspect             Section Mitigating           Green                                     [H.11] -           71111.15 Systems               FIN 05000280,05000281/2021004-01 Challenge the Open/Closed                               Unknown The inspectors identified a finding (FIN) of very low safety significance (Green) associated with Dominion Energys failure to implement Spent Fuel Pool Instrumentation Equipment Functionality requirements established in CM-AA-BDB-102, Beyond Design Basis FLEX Equipment Unavailability Tracking, Revision 12. Specifically, Dominion Energy did not recognize the red alarm light identified on May 29, 2021 could not be due to a spurious user input battery life expiration alarm as the station previously disabled these triggers.
Failure to Implement Spent Fuel Pool Instrumentation Equipment Functionality Requirements Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.11] - 71111.15 Systems FIN 05000280,05000281/2021004 - 01 Challenge the Open/Closed Unknown The inspectors identified a finding (FIN) of very low safety significance (Green) associated with Dominion Energys failure to implement Spent Fuel Pool Instrumentation Equipment Functionality requirements established in CM - AA-BDB-102, Beyond Design Basis FL EX Equipment Unavailability Tracking, Revision 12. Specifically, Dominion Energy did not recognize the red alarm light identified on May 29, 2021 could not be due to a spurious user input battery life expiration alarm as the station previously disabled t hese triggers.


=====Description:=====
=====Description:=====
On November 22, 2021, operators on rounds discovered the uninterruptible power supply (UPS) backup battery status-of-charge indicator on 01-FC-CAB-105-2-CABNET, Spent Fuel Pit Wide Range Level Display Cabinet, Channel 2 was blinking red where normally there are five solid green lights (CR1186371). This indicated a reduced state of charge definitively indicating loss of functionality. The red UPS alarm light was also in. This red light was initially identified on rounds on May 29, 2021 (CR1174127). Per the vendor manual the red UPS alarm could be due to battery almost empty, battery not detected, battery replacement required, inadequate remaining backup time, or other user defined parameters. The onboard UPS software records alarms and triggers while continuously monitoring battery charge, health, and function to adapt UPS performance to maximize battery needs.
On November 22, 2021, operators on rounds discovered the uninterruptible power supply (UPS) backup battery status -of-charge indicator on 01-FC-CAB-105-2-CABNET, Spent Fuel Pit Wide Range Level Display Cabinet, Channel 2 was blinking red where normally there are five solid green lights (CR1186371). This indicated a reduced state of charge definitively indicating loss of functionality. The red UPS alarm light was also in. This red light was initially identified on rounds on May 29, 2021 (CR1174127). Per the vendor manual the red UPS alarm could be due to battery almost empty, battery not detected, battery replacement required, inadequate remaining backup time, or other user defined parameters. The onboard UPS software records alarms and triggers while continuously monitoring battery charge, health, and function to adapt UPS performance to maximize battery needs.


Spent Fuel Pit Wide Range Level Display Cabinets were installed in accordance with NRC Order EA-12-051 wherein the Commission found that, [d]uring the events in Fukushima, responders were without reliable instrumentation to determine water level in the spent fuel pool. This caused concerns that the pool may have boiled dry, resulting in fuel damage.
Spent Fuel Pit Wide Range Level Display Cabinets were installed in accordance with NRC Order EA-12-051 wherein the Commission found that, [d]uring the events in Fukushima, responders were without reliable instrumentation to determine water level in the spent fuel pool. This caused concerns that the pool may have boiled dry, resulting in fuel damage.


Fukushima demonstrated the confusion and misapplication of resources that can result from beyond-design-basis external events when adequate instrumentation is not available. Within this order, the NRC further required, [o]nsite generators used as an alternate power source and replaceable batteries used for instrument channel power shall have sufficient capacity to maintain the level indication function until offsite resource availability is reasonably assured.
Fukushima demonst rated the confusion and misapplication of resources that can result from beyond-design-basis external events when adequate instrumentation is not available. Within this order, the NRC further required, [o]nsite generators used as an alternate power sourc e and replaceable batteries used for instrument channel power shall have sufficient capacity to maintain the level indication function until offsite resource availability is reasonably assured.


The UPS battery backups provide for 72 hours of power to the level indication.
The UPS battery backups provide for 72 hours of power to the level indication.


Dominion Energy developed CM-AA-BDB-102, Beyond Design Basis FLEX Equipment Unavailability Tracking, Revision 12, to meet the commitments of EA-12-051. CM-AA-BDB-102, Attachment 2, FLEX Strategy Equipment Unavailability Requirements, Spent Fuel Pool Instrumentation - Equipment Functionality (NEI 12-02), provides, The primary or back-up instrument channel can be Out-of-Service for testing, maintenance, and/or calibration for up to 90 days provided the other channel is functional. Additionally, compensatory actions must be taken if the instrumentation channel is NOT expected to be restored or is NOT restored within 90 days.
Dominion Energy developed CM -AA-BDB-102, Beyond Design Basis FLEX Equipment Unavailability Tracking, Revision 12, to meet the commitments of EA -12- 051. CM-AA-BDB-102, Attachment 2, FLEX Strategy Equipment Unavailability Requirements, Spent Fuel Pool Instrumentation - Equipment Functionality (NEI 12 -02), provides, The primary or back -up instrument channel can be Out -of-Service for testing, maintenance, and/or calibration for up to 90 days provided the other channel is functional. Additionally, compensatory actions must be taken if the instrumentation channel is NOT expected to be restored or is NOT restored within 90 days.


On October 19, 2021, station engineering completed review of the repeat history of 01-FC-CAB-105-02 failures and alarm light indications (CA8504223). This noted that the UPS batteries had recently been replaced on April 13, 2021, following identification of the red alarm light in on rounds on January 17, 2021. CA8504223 further determined that the probable cause of the alarm was the need to adjust the battery replacement date which impacts the alarm set point for user defined time-for-battery-life-expiration. At that time, with the red alarm light in for 143 days, the licensee failed to recognize that they had previously turned off the battery life expiration alarm trigger, as described below, and how that impacted the UPS functionality (CA8504223).
On October 19, 2021, station engineering completed review of the repeat history of 01-FC-CAB-105-02 failures and alarm light indications (CA8504223). This noted that the UPS batteries had recently been replaced on April 13, 2021, following identification of the red alarm light in on rounds on January 17, 2021. CA8504223 further determined that the probable cause of the alarm was the need to adjust the battery replacement date which impacts the alarm set point for user defined time-fo r-battery-life-expiration. At that time, with the red alarm light in for 143 days, the licensee failed to recognize that they had previously turned off the battery life expiration alarm trigger, as described below, and how that impacted the UPS functionality (CA8504223).


The inspectors discovered a series of similar alarms and battery maintenance of both Spent Fuel Pit Wide Range Level Display Cabinet UPS Channels 1 & 2 had been documented in summer of 2019 (CR1125899 & CR1128332). To preclude future spurious red alarm lights, on August 27, 2019, the licensee turned off the user defined time-for-battery-life-expiration alarm trigger, crediting the remaining associated alarms to indicate battery or UPS failure.
The inspectors discovered a series of similar alarms and battery maintenance of both Spent Fuel Pit Wide Range Level Display Cabinet UPS Channels 1 & 2 had been documented in summer of 2019 (CR1125899 & CR1128332). To preclude future spurious red alarm lights, on August 27, 2019, the licensee turned off the user defined time-for-battery-life-expiration alarm trigger, crediting the remaining associated alarms to indicate battery or UPS failure.
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=====Performance Assessment:=====
=====Performance Assessment:=====
Performance Deficiency: The inspectors found that Dominion Energys failure to implement Spent Fuel Pool Instrumentation Equipment Functionality requirements established in CM-AA-BDB-102 following identification of red UPS alarm light in on May 29, 2021 until loss of all charge failure on November 22, 2021 was a performance deficiency reasonably within the licensees capability to foresee and prevent.
Performance Deficiency: The inspectors found that Dominion Energys failure to implement Spent Fuel Pool Instrumentation Equipment Functionality requirements established in CM -
AA-BDB-102 following identification of red UPS alarm light in on May 29, 2021 until loss of all charge failure on November 22, 2021 was a performance deficiency reasonably within the licensees capability to foresee and prevent.


Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, since alarm discovery in May 2021 until loss of charge in November 2021, the station mischaracterized the probable cause of the UPS alarm as a spurious user defined battery life expiration trigger which inspectors identified had been previously defeated. This actual failure condition indicated by the alarm had the potential to challenge spent fuel pit level instrument channel 2 power capacity to maintain the level indication. A function required until offsite resource availability can be reasonably assured as intended under Order EA-12-051 commitments.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, since alarm discovery in May 2021 until loss of charge in November 2021, the station mischaracterized the probable cause of the UPS alarm as a spurious user defined battery life expi ration trigger which inspectors identified had been previously defeated. This actual failure condition indicated by the alarm had the potential to challenge spent fuel pit level instrument channel 2 power capacity to maintain the level indication. A function required until offsite resource availability can be reasonably assured as intended under Order EA -12-051 comm itm ents.


Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. This finding is associated with spent fuel pool level instrumentation required by Order EA-12-051.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At -Power.


Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. The abnormal indication, red UPS alarm light in, was attributed to an indication problem. Dominion Energy did not thoroughly investigate the prior maintenance activity that disabled the user defined battery life expiration trigger before proceeding.
This finding is associated with spent fuel pool level instrumentation required by Order EA -12-051.
 
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding.
 
The abnormal indication, red UPS alarm light in, was attributed to an indication problem. Dominion Energy did not thoroughly investigate the prior maintenance activity that disabled the user defined battery life expiration trigger before proceeding.


=====Enforcement:=====
=====Enforcement:=====
Inspectors did not identify a violation of regulatory requirements associated with this finding.
Inspectors did not identify a violation of regulatory requirements associated with this finding.


Unresolved Item       Assessment of the Trip Hook Latch-up of the Unit 2 Turbine 71111.19 (Open)               Driven Auxiliary Feedwater Pump URI 05000281/2021004-02
Unresolved Item Assessment of the Trip Hook Latch -up of the Unit 2 Turbine 71111.19 (Open) Driven Auxiliary Feedwater Pump URI 05000281/2021004 -02


=====Description:=====
=====Description:=====
On December 1, 2021, the licensee completed post maintenance testing of the Unit 2 turbine-driven auxiliary feedwater (TDAFW) pump train following performance of Auxiliary Feed Pump Terry Turbine Overspeed Trip Device Inspection, Overhaul, and Adjustment. Following the testing, the associated trip throttle valve trip hook latch-up mechanism was left approximately 50% engaged. Operations recognized that they were unable to meet procedural guidance which states, in part, Check status of TRIP HOOK - full engagement with LATCH UP LEVER (The surface area contact of the latching faces of the TRIP HOOK and the LATCH UP LEVER should be at least 75%). Operations generated CR1187069 to capture the condition.
On December 1, 2021, the licensee completed post maintenance testing of the Unit 2 turbine-driven auxiliary feedwater (TDAFW) pump train following performance of Auxiliary Feed Pump Terry Turbine Overspeed Trip Device Inspection, Overhaul, and Adjustment. Following the testing, the associated trip throttle valve trip hook latch-up mechanism was left approximately 50% engaged. Operations recognized that they were unable to meet procedural guidance w hich states, in part, Check status of TRIP HOOK - full engagement with LATCH UP LEVER (The surface area contact of the latching faces of the TRIP HOOK and the LATCH UP LEVER should be at least 75%). Operations generated CR1187069 to capture the condition.
The trip hook latch up mechanism holds the latch up lever in the up position. When the turbine trips on overspeed, the trip mechanism pulls the trip hook away from the latch up lever. This causes the trip throttle valve to rapidly close removing steam i nput from the turbine and stopping the pump. Improper engagement of the trip hook latch up mechanism can result in spurious closure of the trip throttle valve causing failures of the pump to start or run when required to respond to an event.


The trip hook latch up mechanism holds the latch up lever in the up position. When the turbine trips on overspeed, the trip mechanism pulls the trip hook away from the latch up lever. This causes the trip throttle valve to rapidly close removing steam input from the turbine and stopping the pump. Improper engagement of the trip hook latch up mechanism can result in spurious closure of the trip throttle valve causing failures of the pump to start or run when required to respond to an event.
Station engineering reviewed CR1187069 and used engineering judgement to assert that a valve spring within the latch-up linkage mechanism would prevent any further inadvertent motion of the trip hook based upon its applied pressure. Operations used this input to establish the full engagement status check as completed satisfactory.


Station engineering reviewed CR1187069 and used engineering judgement to assert that a valve spring within the latch-up linkage mechanism would prevent any further inadvertent motion of the trip hook based upon its applied pressure. Operations used this input to establish the full engagement status check as completed satisfactory. Station engineering further recommended the engagement be adjusted to 75% during the next quarterly test of the component, noting that the procedural requirement for 75% engagement was incorporated from vendor and other industry design standards.
Station engineering further recommended the engagement be adjusted to 75% during the next quarterly test of the component, noting that the procedural requirement for 75% engagement was incorporated from vendor and other industry design standards.


The inspectors observed that the station had previously updated the design basis to incorporate revised requirements (e.g., 75%) for trip hook latch-up mechanism following a similar event in 2017 (CR1073366). The inspectors identified that this current assessment did not address how the spring pressure allowed the latch mechanism to be less engaged than the design basis acceptance criteria. Furthermore, it did not address the actual amount of engagement or its impact on preventing spurious overspeed trips or the potential inability to reset from an overspeed trip, as described in the design basis incorporated following the similar event in 2017.
The inspectors observed that the station had previously updated the design basis to incorporate revised requirements (e.g., 75%) for trip hook latch-up mechanism following a similar event in 2017 (CR1073366). The inspectors identified that this current assessment did not address how the spring pressure allowed the latch mechanism to be less engaged than the design basis acceptance criteria. Furthermore, it did not address the actual amount of engagem ent or its impact on preventing spurious overspeed trips or the potential inability to reset from an overspeed trip, as described in the design basis incorporated following the similar event in 2017.


Given the TDAFW pump trains heat sink safety function associated with a loss of AC power event, the inspectors discussed their concerns with station management. On December 3, 2021, the station ran the TDAFW pump train. When attempting to reset the trip hook latch-up linkage, they, again, observed 50% engagement during the full engagement status check.
Given the TDAFW pump trains heat sink safety function a ssociated with a loss of AC power event, the inspectors discussed their concerns with station management. On December 3, 2021, the station ran the TDAFW pump train. When attempting to reset the trip hook latch-up linkage, they, again, observed 50% engageme nt during the full engagement status check.


The station again concluded that Engineering does not have concern that the Unit 2 Terry Turbine will not be able to perform its design function based on observations during 2-OP-FW-002.
The station again concluded that Engineering does not have concern that the Unit 2 Terry Turbine will not be able to perform its design function based on observations during 2-OP-FW-002.
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The inspectors found that Dominion Energys failure to maintain the unit 2 TDAFW trip hook latch-up mechanism in accordance with test and operating procedures was a performance deficiency reasonably within the licensees ability to foresee and prevent. Specifically, on multiple occasions station engineering used engineering judgement inconsistent with the design basis to justify acceptance of trip hook latch-up mechanism engagement of 50% when greater than 75% engagement was required.
The inspectors found that Dominion Energys failure to maintain the unit 2 TDAFW trip hook latch-up mechanism in accordance with test and operating procedures was a performance deficiency reasonably within the licensees ability to foresee and prevent. Specifically, on multiple occasions station engineering used engineering judgement inconsistent with the design basis to justify acceptance of trip hook latch-up mechanism engagement of 50% when greater than 75% engagement was required.


Planned Closure Actions: The licensee has established a corrective action (CA9212266) to engage with the vendor subject matter experts on the applicability of the trip hook latch-up requirements established within the design basis. The licensee believes greater margin exists within the full engagement criteria described. Upon completion of this activity planned within the first calendar quarter of 2022, the inspectors will review the results of CA9212266 to provide input on the more than minor determination associated with the identified performance deficiency.
Planned Closure Actions: The licensee has established a corrective action (CA9212266) to engage with the vendor subject matter experts on the applicability of the trip hook latch-up requirements established within the design basis. The licensee believes greater margin exists within the full enga gement criteria described. Upon completion of this activity planned within the first calendar quarter of 2022, the inspectors will review the results of CA9212266 to provide input on the more than minor determination associated with the identified performance deficiency.


Licensee Actions: The station performed troubleshooting on December 9, 2021 under WO#38204281432. This activity discovered lose set screws within the latch up mechanism.
Licensee Actions: The station performed troubleshooting on December 9, 2021 under WO#38204281432. This activity discovered lose set screws within the latch up mechanism.
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Following tightening, the station performed post maintenance testing. With the linkage properly aligned, Operators attained 100% surface area contact when resetting the trip throttle valve latch-up mechanism.
Following tightening, the station performed post maintenance testing. With the linkage properly aligned, Operators attained 100% surface area contact when resetting the trip throttle valve latch-up mechanism.


Corrective Action References: CR1073366, CR1189974, CA9212266 Observation: Trend Review of Foreign Material Exclusion                              71152 The inspectors performed a review of potential adverse trends in foreign material exclusion that might be indicative of a more significant safety issue. The inspectors performed interviews and sampled a population of maintenance records, documented inspections, condition reports, and log entries during the period of January 1, 2021 through December 31, 2021.
Corrective Action References: CR1073366, CR1189974, CA9212266


Based upon the samples reviewed, the inspectors found that there was an apparent increasing trend in adverse foreign material exclusion events between unit refueling outages.
Observation: Trend Review of Foreign Material Exclusion 71152 The inspectors performed a review of potential adverse trends in foreign material exclusion that might be indicative of a more significant safety issue. The inspectors performed interviews and sampled a population of maintenance records, documented inspections,
condition reports, and log entries during the period of January 1, 2021 through December 31, 2021.
 
Based upon the samples reviewed, the inspectors found that there was an apparent increasing trend in adverse foreign material exclusion events between uni t refueling outages.


However, the station performance improvement team properly identified the need for trend review upon reaching condition and performance monitoring thresholds generating corrective actions consistent with their programs. The inspectors did not identify any findings as a result of this inspection.
However, the station performance improvement team properly identified the need for trend review upon reaching condition and performance monitoring thresholds generating corrective actions consistent with their programs. The inspectors did not identify any findings as a result of this inspection.
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==EXIT MEETINGS AND DEBRIEFS==
==EXIT MEETINGS AND DEBRIEFS==
The inspectors verified no proprietary information was retained or documented in this report.
The inspectors verified no proprietary information was retained or documented in this report.
* On January 31, 2022, the inspectors presented the integrated inspection results to Johnny Henderson, Director of Safety and Licensing, and other members of the licensee staff.
* On January 31, 2022, the inspector s presented the integrated inspection results to Johnny Henderson, Director of Safety and Licensing, and other members of the licensee staff.


THIRD PARTY REVIEWS Inspectors reviewed Management Safety Review Committee reports that were issued during the inspection period.
THIRD PARTY REVIEWS
 
Inspectors reviewed Management Safety Review Committee reports that were issued during the inspection period.


=DOCUMENTS REVIEWED=
=DOCUMENTS REVIEWED=


Inspection Type             Designation     Description or Title                                     Revision or
Inspection Type Designation Description or Title Revision or
Procedure                                                                                             Date
Procedure Date
71111.04   Corrective Action CR1184906       NRC Identified questions/issues in U2 containment and Aux 11/07/2021
71111.04 Corrective Action CR1184906 NRC Identified questions/issues in U2 containment and Aux 11/07/2021
Documents
Docum ents
Resulting from
Resulting from
Inspection
Inspection
Drawings         11548-FP-13C   Containment & Recirc Spray System SH.3                   Rev 005
Drawings 11548-FP-13C Containment & Recirc Spray System SH.3 Rev 005
Engineering       PTR-           Commercial Grade Dedication Plan - Diesel Fuel Oil       1
Engineering PTR-Commercial Grade Dedication Plan - Diesel Fuel Oil 1
Evaluations       10000032901
Evaluations 10000032901
PTR-           Commercial Grade Dedication Plan - Diesel Fuel Oil       3
PTR-Commercial Grade Dedication Plan - Diesel Fuel Oil 3
10000032901
10000032901
Miscellaneous     Commercial     Vendor Programs Commercial Grade Survey of Intertek       06/17/2014
Miscellaneous Commercial Vendor Programs Commercial Grade Survey of Intertek 06/17/2014
Grade Survey
Grade Survey
DS-14-011
DS-14-011
Sample ID 2015- Fuel Oil Report of Analysis                               08/25/2015
Sample ID 2015-Fuel Oil Report of Analysis 08/25/2015
NFLK-000748-
NFLK-000748-
008
008
Sample ID 2015- Fuel Oil Report of Analysis                               08/25/2015
Sample ID 2015-Fuel Oil Report of Analysis 08/25/2015
NFLK-000748-
NFLK-000748-
008
008
Sample ID 2015- Fuel Oil Report of Analysis                               11/23/2015
Sample ID 2015-Fuel Oil Report of Analysis 11/23/2015
NFLK-000989-
NFLK-000989-
001
001
Sample ID 2015- Fuel Oil Report of Analysis                               11/24/2015
Sample ID 2015-Fuel Oil Report of Analysis 11/24/2015
NFLK-000989-
NFLK-000989-
008
008
Sample ID 2015- Fuel Oil Report of Analysis                               11/25/2015
Sample ID 2015-Fuel Oil Report of Analysis 11/25/2015
NFLK-000989-
NFLK-000989-
2
2
Sample ID 2021- Fuel Oil Report of Analysis                               08/02/2021
Sample ID 2021-Fuel Oil Report of Analysis 08/02/2021
NFLK-000465-
NFLK-000465-
003
003
Sample ID 2021- Fuel Oil Report of Analysis                               08/02/2021
Sample ID 2021-Fuel Oil Report of Analysis 08/02/2021
NFLK-000465-
NFLK-000465-
Inspection Type             Designation     Description or Title                                       Revision or
Inspection Type Designation Description or Title Revision or
Procedure                                                                                               Date
Procedure Date
005
005
Sample ID 2021- Fuel Oil Report of Analysis                               08/02/2021
Sample ID 2021-Fuel Oil Report of Analysis 08/02/2021
NFLK-000465-
NFLK-000465-
013
013
Procedures       2-OP-RH-001A     RHR System Valve Alignment                                 Rev 7
Procedures 2-OP-RH-001A RHR System Valve Alignment Rev 7
CY-AA-AUX-310   Diesel Fuel Oil Sampling and Testing                       13
CY-AA-AUX-310 Diesel Fuel Oil Sampling and Testing 13
VPAP-2205       Diesel Fuel Oil Testing Program                           6
VPAP-2205 Diesel Fuel Oil Testing Program 6
71111.05   Procedures       0-FS-FP-122     Fire Pre-Plan, Diesel Generator Room Number 2, Elevation   2
71111.05 Procedures 0-FS-FP-122 Fire Pre-Plan, Diesel Generator Room Number 2, Elevation 2
feet - 6 inches
feet - 6 inches
0-FS-FP-224     Fire Pre-Plan, Mechanical Equipment Room (MER 5),         4
0-FS-FP-224 Fire Pre-Plan, Mechanical Equipment Room (MER 5), 4
Elevation 27 feet - 6 inches
Elevation 27 feet - 6 inches
71111.08P Corrective Action CA 7665977       Corrective Action (CA) to Engineering to update documents 8/20/19
71111.08P Corrective Action CA 7665977 Corrective Action (CA) to Engineering to update documents 8/20/19
Documents                          (ER-SU-AUG-101 and AMP) as required
Docum ents (ER-SU-AUG-101 and AMP) as required
CA 7726026       A new Augmented Plan (ER-SU-AUG-101) should be             111/1/19
CA 7726026 A new Augmented Plan (ER-SU-AUG-101) should be 111/1/19
created to enhance specifications for
created to enhance specifications for
examination requirements based on TB-19-5.
examination requirements based on TB-19-5.
CR-1176685       ASME Section XI IWL Unit 2 Inspection Indications 2021     07/12/2021
CR-1176685 ASME Section XI IWL Unit 2 Inspection Indications 2021 07/12/2021
CR-1183591       2-RH-P-1B RHR PUMP Boric Acid Evaluation                   11/7/21
CR-1183591 2-RH-P-1B RHR PUMP Boric Acid Evaluation 11/7/21
CR-1183703       Boric Acid found on weld 2-CH-PT-3642 (potential thru-weld 10/25/21
CR-1183703 Boric Acid found on weld 2-CH-PT-3642 (potential thru-weld 10/25/21
leak, 3/8-inch tubing)
leak, 3/8-inch tubing)
CR-1183717       Boric Acid Evaluation Valve 2-SI-91, IAW Code Case N-566   11/5/21
CR-1183717 Boric Acid Evaluation Valve 2-SI-91, IAW Code Case N-566 11/5/21
CR-1183843       Boric Acid Evaluation of 2-RH-19, IAW Code Case N-566-2   11/8/21
CR-1183843 Boric Acid Evaluation of 2-RH-19, IAW Code Case N-566-2 11/8/21
PA 7560972       Evaluate/Implement Needed Requirements of MRP 2019-       4/4/19
PA 7560972 Evaluate/Implement Needed Requirements of MRP 2019-4/4/19
008
008
Engineering       51-9334439-000   Site Validation of EPRI Qualified Eddy Current Techniques 10/31/21
Engineering 51-9334439-000 Site Validation of EPRI Qualified Eddy Current Techniques 10/31/21
Evaluations                       for Surry 2R30
Evaluations for Surry 2R30
ETE-CEP-2021-   Steam Generator Degradation .Assessment, Surry Unit 2     Fall 2021
ETE-CEP-2021-Steam Generator Degradation.Assessment, Surry Unit 2 Fall 2021
1011             Refueling Outage 2R30
1011 Refueling Outage 2R30
ETE-SU-2021-     Surry Unit-2, MRP-227-1-A Reactor Vessel Internals         11/12/21
ETE-SU-2021-Surry Unit-2, MRP-227-1-A Reactor Vessel Internals 11/12/21
0055             Examinations, Engineering Evaluation- Phase 1
0055 Examinations, Engineering Evaluation-Phase 1
Miscellaneous     51-9333405 - 000 Surry Unit 2, 2R30 Steam Generator ECT Examination         9/17/21
Miscellaneous 51-9333405 - 000 Surry Unit 2, 2R30 Steam Generator ECT Examination 9/17/21
Inspection Type Designation       Description or Title                                 Revision or
 
Procedure                                                                               Date
Inspection Type Designation Description or Title Revision or
Procedure Date
Inspection Plan
Inspection Plan
Boric Acid       Qualifications                                       11/10/21
Boric Acid Qualifications 11/10/21
Inspector
Inspector
PETER05
PETER05
Docket Nos.: 50- Proposed License Amendment Request One-Time Deferral 4/14/20
Docket Nos.: 50- Proposed License Amendment Request One -Time Deferral 4/14/20
280/281, Letter   of Surry Unit-2 Steam Generator "B" Inspection
280/281, Letter of Surry Unit -2 Steam Generator "B" Inspection
Serial No. 20-136
Serial No. 20-136
ID No.: 03-       Steam Generator Tube - Rolled Tube Plug & Stabilizer   Rev. 4
ID No.: 03-Steam Generator Tube - Rolled Tube Plug & Stabilizer Rev. 4
9315755           Installation (ZR) Field Procedure
9315755 Installation (ZR) Field Procedure
NDE Inspector     Certificate of Personnel Qualification               7/29/21
NDE Inspector Certificate of Personnel Qualification 7/29/21
ID: B0861
ID: B0861
NDE Inspector ID Ultrasonic Testing Certification                     Exp. Date
NDE Inspector ID Ultrasonic Testing Certification Exp. Date
No.: 3351                                                               1/13/23
No.: 3351 1/13/23
NDE Inspector ID Certificate of Personnel Qualification               10/17/21
NDE Inspector ID Certificate of Personnel Qualification 10/17/21
No.: 57120
No.: 57120
NDE Inspector ID Certificate of Personnel Qualification               9/0/21
NDE Inspector ID Certificate of Personnel Qualification 9/0/21
No.: C5341
No.: C5341
NDE Personnel     IWE, VT Level II Examiner (ID Initials D.V.R)         1/24/20
NDE Personnel IWE, VT Level II Examiner (ID Initials D.V.R) 1/24/20
Qualification and
Qualification and
Certification
Certification
Record
Record
Surry ISI         Interval Completion Summary Status                   November
Surry ISI Interval Completion Summary Status Novem ber
Standard Plan                                                           2021
Standard Plan 2021
                (Baseline)
(Baseline)
Standard Code
Standard Code
ASME XI, 2004Ed
ASME XI, 2004Ed
Surry Tech Spec   One -Time Deferral of Surry Unit-2 Steam Generator B" 5/7/2020
Surry Tech Spec One -Time Deferral of Surry Unit-2 Steam Generator B" 5/7/2020
Amendment No. Spring 2020 Refueling Outage Inspection (EPID NO. L-
Amendm ent No. Spring 2020 Refueling Outage Inspection (EPID NO. L-
299               2019-LLA-0071)
299 2019-LLA-0071)
Tech Spec 6.4-   Steam Generator Program                               1/28/13
Tech Spec 6.4-Steam Generator Program 1/28/13
Q
Q
Virginia Electric SURRY POWER STATION, UNIT2, INSERVICE                 MAY10,
Virginia Electric SURRY POWER STATION, UNIT2, INSERVICE MAY10,
and Power         INSPECTION PLAN FOR COMPONENTS AND                   2014 - MAY
and Power INSPECTION PLAN FOR COMPONENTS AND 2014 - MAY
Company           COMPONENT SUPPORTS, FIFTH 10-YEAR INSERVICE           9, 2024
Company COMPONENT SUPPORTS, FIFTH 10-YEAR INSERVICE 9, 2024
Inspection Type       Designation       Description or Title                                     Revision or
 
Procedure                                                                                         Date
Inspection Type Designation Description or Title Revision or
                      (Dominion), Serial INSPECTION INTERVAL
Procedure Date
(Dominion), Serial INSPECTION INTERVAL
No. 14-
No. 14-
194,Docket No.
194,Docket No.
50-281
50- 281
NDE Reports NDE Report No. UT Examination, Component ID No.11548-WMKS-0127J3 /     11/15/21
NDE Reports NDE Report No. UT Exam ination, Com ponent ID No.11548-WMKS-0127J3 / 11/15/21
ISI-2-UT-21-030   6-RC-320 / 1-038, Valve to Elbow Weld
ISI-2-UT-21-030 6-RC-320 / 1-038, Valve to Elbow Weld
NDE Rpt. No. -     PT Results, 02-CH-ICV-3642-VALV, Tubing Fitting, Weld   11/11/21
NDE Rpt. No. - PT Results, 02-CH-ICV-3642-VALV, Tubing Fitting, Weld 11/11/21
BOP-PT-21-157     Repair
BOP-PT-21-157 Repair
NDE Rpt. No. ISI- Integral attachment of Component ID 11548-WMKS-         11/5/21
NDE Rpt. No. ISI-Integral attachment of Component ID 11548 -WMKS-11/5/21
2-PT-21-010       0117A1-1 / 14-RH-101 / H016-2
2-PT-21-010 0117A1-1 / 14-RH-101 / H016-2
Report No.: ISl-2- UT Examination of Component ID: 11548-WMKS-0117A1 -1     11/8/21
Report No.: ISl-2-UT Exam ination of Com ponent ID: 11548-WMKS-0117A1 -1 11/8/21
UT-21-019         / 14-RH-101 / 1-03, Elbow to Pipe, RH System
UT-21-019 / 14-RH-101 / 1-03, Elbow to Pipe, RH System
Rpt. No. ISI-2-   Magnetic Particle (MT) Examination of Comp ID No. 11548- 11/15/21
Rpt. No. ISI-2-Magnetic Particle (MT) Examination of Comp ID No. 11548 - 11/15/21
MT-21-011         WMKS-0103A2-1 / 30-SHP-122 / H03
MT-21- 011 WMKS-0103A2-1 / 30-S HP-122 / H03
Summary No.       IWE Examination, Comp. ID, 11548-IWE/E1.11A, Floor Slab 11/16/21
Summary No. IWE Exam ination, Comp. ID, 11548-IWE/E1.11A, Floor Slab 11/16/21
2.EI.11 A .001   to Metal Liner Interface Area
2.EI.11 A.001 to Metal Liner Interface Area
Procedures 54-131-370-008     Remote Underwater Visual Examination of PWR Reactor     8/27/21
 
Procedures 54-131-370-008 Remote Underwater Visual Examination of PWR Reactor 8/27/21
Pressure Vessel Internals in Accordance with MRP 227 &
Pressure Vessel Internals in Accordance with MRP 227 &
28
28
Doc. No.: 03-     Field Procedure for Performing CRGT Guide Card Wear     Rev. 003
Doc. No.: 03-Field Procedure for Performing CRGT Guide Card Wear Rev. 003
259968           Measurements
259968 Measurements
ER-AA-NDE-UT-     Ultrasonic Examination of Austenitic Piping Welds in     Rev. 8
ER-AA-NDE-UT-Ultrasonic Examination of Austenitic Piping Welds in Rev. 8
2               Accordance with ASME
2 Accordance with ASME
Section XI, Appendix VIII
Section XI, Appendix VIII
ER-AA-NDE-VT-     IWE Visual Examination Procedure                         Rev.3
ER-AA-NDE-VT-IWE Visual Examination Procedure Rev.3
605
605
ER-AP-BAC-10       Boric Acid Corrosion Control Program                     Rev. 14
ER-AP-BAC-10 Boric Acid Corrosion Control Program Rev. 14
ER-AP-BAC-101     Boric Acid Corrosion Control Program (BACCP) Inspections Rev. 14
ER-AP-BAC-101 Boric Acid Corrosion Control Program (BACCP) Inspections Rev. 14
Inspection Type             Designation     Description or Title                                     Revision or
 
Procedure                                                                                               Date
Inspection Type Designation Description or Title Revision or
ER-AP-BAC-102   Boric Acid Corrosion Control Program (BACCP) Evaluations Rev. 16
Procedure Date
ER-SU-AUG-101   Surry Augmented Inspection Program                       Rev. 19
ER-AP-BAC-102 Boric Acid Corrosion Control Program (BACCP) Evaluations Rev. 16
SRY-SGPMS-002   SURRY SITE SPECIFIC EDDY CURRENT ANALYSIS                 Rev. 30
ER-SU-AUG-101 Surry Augmented Inspection Program Rev. 19
SRY-SGPMS-002 SURRY SITE SPECIFIC EDDY CURRENT ANALYSIS Rev. 30
GUIDELINES
GUIDELINES
Self-Assessments  PI-AA-100-1004, Review of the Steam Generator Program                     ????
Self-A sse ssm en t s PI-AA-100-1004, Review of the Steam Generator Program ????
2,
Attachm ent 2,
PIR-1030006
PIR-1030006
Assessment No. Provide a review of the Reactor Coolant System, Material Surry , June
Assessment No. Provide a review of the Reactor Coolant System, Material Surry, June
PIR1119200       Degradation Management Program                           19-22, 2017
PIR1119200 Degradation Management Program 19-22, 2017
PIR 1079417     Fleet Inservice Inspection Program Formal Self-Assessment 1/24/18
PIR 1079417 Fleet Inservice Inspection Program Formal Self-Assessment 1/24/18
71111.11Q Miscellaneous                       Emergency Preparedness Drill Guide                       10/14/2021
71111.11Q Miscellaneous Emergency Preparedness Drill Guide 10/14/2021
Procedures       2-GOP-2.2       Unit Shutdown, Less than 30% to Hot Shutdown             52
Procedures 2-GOP-2.2 Unit Shutdown, Less than 30% to Hot Shutdown 52
2-OP-RH-001     Residual Heat Removal Operations                         30
2-OP-RH-001 Residual Heat Removal Operations 30
71111.12   Corrective Action CA8816961
71111.12 Corrective Action CA8816961
Documents        CR1184906
Docum ents CR1184906
Resulting from
Resulting from
Inspection
Inspection
71111.13   Miscellaneous     Unit 2 Outage                                                             10/20/2021
71111.13 Miscellaneous Unit 2 Outage 10/20/2021
Risk Assessment
Risk Assessment
Unit 2 Outage                                                             10/26/2021
Unit 2 Outage 10/26/2021
Risk Assessment
Risk Assessment
Unit 2 Outage                                                             11/21/2021
Unit 2 Outage 11/21/2021
Risk Assessment
Risk Assessment
Unit 2 Outage                                                             11/29/2021
Unit 2 Outage 11/29/2021
Risk Assessment
Risk Assessment
71111.19   Procedures       0-MCM-0113-02   Auxiliary Feedwater Pump Inspection and Maintenance       Rev 21
71111.19 Procedures 0-MCM-0113-02 Auxiliary Feedwater Pump Inspection and Maintenance Rev 21
0-MCM-1403-01   Terry Turbine Overhaul, 1-FW-T-2 and 2-FW-T-2             Rev 28
0-MCM-1403-01 Terry Turbine Overhaul, 1-FW-T-2 and 2-FW-T-2 Rev 28
0-MCM-1403-01   TERRY TURBINE OVERHAUL, 1-FW-T-2 AND 2-FW-T-2             28
0-MCM-1403-01 TERRY TURBINE OVERHAUL, 1-FW-T-2 AND 2-FW-T-2 28
0-MCM-1403-02   AUXILIARY FEED PUMP TERRY TURBINE OVERSPEED               15
0-MCM-1403-02 AUXILIARY FEED PUMP TERRY TURBINE OVERSPEED 15
TRIP DEVICE INSPECTION, OVERHAUL, AND
TRIP DEVICE INSPECTION, OVERHAUL, AND
ADJUSTMENT
ADJUSTMENT
2-OPT-EG-009     Number 2 Emergency Diesel Generator Major Maintenance     Rev 64
2-OPT-EG-009 Number 2 Emergency Diesel Generator Major Maintenance Rev 64
Operability Test
Operability Test
2-OPT-FW-003     Turbine Driven Auxiliary Feedwater Pump 2-FW-P-2         Rev 70
2-OPT-FW-003 Turbine Driven Auxiliary Feedwater Pump 2-FW-P-2 Rev 70
Inspection Type             Designation     Description or Title                                     Revision or
 
Procedure                                                                                             Date
Inspection Type Designation Description or Title Revision or
2-OPT-FW-007   Turbine Driven AFW Pump Steam Supply Line Check Valve     Rev 7
Procedure Date
2-OPT-FW-007 Turbine Driven AFW Pump Steam Supply Line Check Valve Rev 7
test
test
Work Orders       38204218250     547 Day Freq. PT: EDG 2 Major Maintenance Operability     11/05/2021
Work Orders 38204218250 547 Day Freq. PT: EDG 2 Major Maintenance Operability 11/05/2021
Test
Test
71111.20   Miscellaneous     S2C31 Full Core                                                           Revision 0
71111.20 Miscellaneous S2C31 Full Core Revision 0
Loading Map
Loading Map
Procedures       2-GOP-1.4       Unit Startup, Hot Shutdown to 2% Reactor Power           59
Procedures 2-GOP-1.4 Unit Startup, Hot Shutdown to 2% Reactor Power 59
2-GOP-2.2       Unit Shutdown, Less than 30% to Hot Shutdown             52
2-GOP-2.2 Unit Shutdown, Less than 30% to Hot Shutdown 52
2-MCM-1150-01   Unit 2 Reactor Vessel Disassembly and Reassembly         45
2-MCM-1150-01 Unit 2 Reactor Vessel Disassembly and Reassembly 45
2-OP-RC-004     Draining the Reactor Coolant System to Reactor Flange     44
2-OP-RC-004 Draining the Reactor Coolant System to Reactor Flange 44
Level
Level
2-OP-RH-001     Residual Heat Removal Operations                         30
2-OP-RH-001 Residual Heat Removal Operations 30
71111.22   Procedures       2-OPT-CT-201   Containment Isolation Valve Local Leak Rate Testing (Type Rev 23
71111.22 Procedures 2-OPT-CT-201 Containment Isolation Valve Local Leak Rate Testing (Type Rev 23
C Containment Testing)
C Containment Testing)
2-OPT-EG-001   Number 2 Emergency Diesel Generator Monthly Start         84
2-OPT-EG-001 Number 2 Emergency Diesel Generator Monthly Start 84
Exercise Test
Exercise Test
Work Orders       38204209707     Perform 1-OPT-RS-001, Outside recirculation spray pump   05/03/2021
Work Orders 38204209707 Perform 1-OPT-RS-001, Outside recirculation spray pump 05/03/2021
flow and leak test on November 9, 2021
flow and leak test on November 9, 2021
204219904     547 Day Freq. PT: Cont. Isol. Vlv. Local Leak Rate test
204219904 547 Day Freq. PT: Cont. Isol. Vlv. Local Leak Rate test
                                            (Type C) - OC-23B 2-OPT-CT-201
(Type C) - OC-23B 2-OPT-CT-201
71151     Miscellaneous                     Consolidated Data Entry Derivation and Margin Reports for
71151 Miscellaneous Consolidated Data Entry Derivation and Margin Reports for
Surry Power Station Mitigating System Performance Index
Surry Power Station Mitigating System Performance Index
Performance Indicators 2018 through 2021.
Performance Indicators 2018 through 2021.
71152     Corrective Action CR1164749,     Foreign Material Exclusion condition reports
71152 Corrective Action CR1164749, Foreign Material Exclusion condition reports
Documents        CR1163901,
Docum ents CR1163901,
CR1163867,
CR1163867,
CR1171442,
CR1171442,
Line 524: Line 568:
CR1173717,
CR1173717,
CR1171978,
CR1171978,
Inspection Type Designation Description or Title Revision or
Inspection Type Designation Description or Title Revision or
Procedure                                       Date
Procedure Date
CR1173624,
CR1173624,
CR1173938,
CR1173938,
Line 548: Line 593:
CR1188042,
CR1188042,
CR1188395
CR1188395
20
20
}}
}}

Latest revision as of 18:19, 18 November 2024

Integrated Inspection Report 05000280/2021004 and 05000281/2021004
ML22040A200
Person / Time
Site: Surry  Dominion icon.png
Issue date: 02/11/2022
From: Stewart Bailey
Division Reactor Projects II
To: Stoddard D
Virginia Electric & Power Co (VEPCO)
References
IR 2021004
Download: ML22040A200 (23)
v • d • e


Text

February 11, 2022

SUBJECT:

SURRY POWER STATION - INTEGRATED INSPECTION REPORT 05000280/2021004 AND 05000281/2021004

Dear Mr. Stoddard:

On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Surry Power Station. On January 31, 2022, the NRC inspectors discussed the results of this inspection with Johnny Henderson, Director of Safety and Licensing, a nd other members of your staff. The results of this inspection are documented in the enclos ed report.

One finding of very low safety si gnificance (Green) is documented in this report. This finding did not involve a violation of NRC requirements.

If you disagree with a cross -cutting aspect assignment or a finding not associat ed with a regulatory requirement 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 th e Regional Administrator, Region II; and the NRC Resident I nspector at Surry Power Station. This letter, its enclosure, and your response (if any) will be m ade available for public inspection and copying at http://www.nrc.gov/reading-rm /a dam s.h tm l 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 Br anch 4 Division of Reactor Projects

Docket Nos. 05000280 and 05000281 License Nos. DPR-32 and DPR-37

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000280 and 05000281

License Numbers: DPR-32 and DPR -37

Report Numbers: 05000280/2021004 and 05000281/2021004

Enterprise Identifier: I-2021- 004-0021

Licensee: Virginia Electric and Power Company

Facility: Surry Power Station

Location: Surry, VA

Inspection Dates: October 1, 2021 to December 31, 2021

Inspectors: D. B a con, Senior Operations Engineer A. Butcavage, Reactor Inspector L. McKown, Senior Resident Inspector B. Towne, Resident Inspector

Approved By: Stewart N. Bailey, Chief Reactor Projects Br anch 4 Division of Reactor Projects

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licens ees 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 Implement Spent Fuel Pool Instrumentation Equipment Functionality Requirements Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.11] - 71111.15 Systems FIN 05000280,05000281/2021004-01 Challenge the Open/Closed Unknown The inspectors identified a finding (FIN) of very low safety significance (Green) associated with Dominion Energys failure to implement Spent Fuel Pool Instrumentation Equipment Functionality requirements established in CM -AA-BDB-102, Beyond Design Basis FLEX Equipment Unavailability Tracking, Revision 12. Specifically, Dominion Energy did not recognize the red alarm light identified on May 29, 2021 could not be due to a spurious user input battery life expiration alarm as the station previously disabled these triggers.

Additional Tracking Items

Type Issue Num ber Title Report Section Status URI 05000281/2021004-02 Assessment of the Trip Hook 71111.19 Open Latch-up of the Unit 2 Turbine Driven Auxiliary Feedwater Pump

PLANT STATUS

Unit 1 operated at or near rated thermal power for the entire inspection period.

Unit 2 began the inspection period at 91 percent rated thermal power in coastdown in advance of the scheduled refueling outage shutdown performed on October 24, 2021. On December 2, 2021, Unit 2 achieved criticality following the outage returning to rated thermal power on Decem ber 5, 2021. Unit 2 operated at or near rated ther mal power for the remainder of 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, conducted routine reviews using IP 71152, Problem Identification and Resolution, 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 condit ions, site procedures, and standards

REACTOR SAFETY

71111.01 - Adverse Weather Protection

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding in December 2021.
  • Safeguards Buildings

71111.04 - Equipm ent Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1) Unit 1 station battery charger alignment during surveillance testing on October 20, 2021.
(2) Unit 1 and 2 emergency diesel fuel oil storage and transfer system on November 2, 2021
(3) Unit 2 recirculation spray containment ring on November 4, 2021.

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 residual heat removal (RHR) system in shutdown cooling alignment on Novem ber 10, 2021.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Sam ples)

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 2 mechanical equipment room #5 on October 19, 2021.
(2) No. 2 emergency diesel generator room on October 19, 2021.
(3) Unit 2 Turbine Building (Basement, Mezzanine, and Deck) on October 26, 2021.
(4) Unit 2 Containment on October 27, 2021.

71111.06 - Flood Protection Measures

Cable Degradation (IP Section 03.02) (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) Cable vaults 1-EP-MH-1, 1-EP-MH-2, 1-EP-MH-3 associated with WO38204216570, on October 24, 2021.

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Unit 1, component cooling water heat exchangers A, B, C, & D, on Decem ber 15, 2021.

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

Main article: IP 71111.08
(1) The inspectors verified that the reactor coolant system boundary, steam generator tubes, reactor vessel internals, risk -significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from11/1/21 to11/30/21:

03.01.a - Nondestructive Examination and Welding Activities.

  • Ultrasonic Exam ination (UT), Com ponent ID: 11548-WMKS-0117A1-1 / 14-RH-101 / 1- 03, Elbow to Pipe Weld, NDE Report ISl -2-UT-21- 019, ASME Class 1
  • Magnetic Particle Exam ination (MT), Com ponent ID: 11548-WMKS-0103A2-1

/ 30-SHP-122 / H0, ASME Class 2

  • Penetrant Examination (PT), Com ponent ID: 11548-WMKS-0117A1-1 / 14-RH-101 / H016-2, Integral Attachments, RH System, ASME Class 2
  • ASME Section. XI, IWE, VT, Comp. ID, 11548 -IWE/E1.11A, Containment Floor Slab to Metal Liner Interface Area

03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities.

  • RVCHVT -2 Leakage exam IAW N -729: Sam ple Penetration Videos for # 14,
  1. 16, #18 and #44. Plus RVLIS and Vent Line Penetrations

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

  • CR1161992, CA8245219, Boric Acid Evaluation for 02-CS--73 -VALVE, Leakage
  • CR1183722, Boric Acid Evaluation IAW N -566-2, for Valve 2-RC-HCV-2557A, Valve Material, and Bolts
  • Review of Initial Containment Walkdown Inspection Results

03.01.d - Pressurized-Water Reactor Steam Generator Tube Examination Activities.

  • Site Eddy Current Examinations on: Sg "2A",SG "2B", SG "2C", in accordance with Document No.: 51-9333405-000
  • Observations SG "C" Hot Leg Row 6, Col. 48,
  • Observations SG "B" HL Row 42, Col, 40, Row 10, Col 58, Row21, Col 21.
  • Site Secondary side visual examinations] SG "2A" '2B" "2C"

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The licensee completed the requalification annual operating tests 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 December 6, 2021, the inspector performed an in-office review of the overall pass/fail results of the individual operating tests and crew simulator operating tests in accordance with Inspection Procedure (IP)

===71111.11, "Licensed Operator Requalification Program." These results were compared to the thresholds established in Section 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 tests completed on March 11, 2021.

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 the planned shutdown for Unit 2 fall refueling outage on October 24, 2021

Licensed Operator Requalification Training/Examinations (IP Section 03.02)===

Main article: IP 71111.11
(1) The inspectors observed and evaluated operations in the simulator during an Emergency Preparation drill including a tornado in the switchyard, partial loss of all AC power, and a small break loss of coolant accident on October 14, 2021.

71111.12 - Maintenance Effectiveness

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 2 recirculation spray nozzles on November 4, 2021.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (6 Sam ples)

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) Change in risk at Unit 2 high level intake structure due to emergent failure of hose house #15 hydrant (CR1182734) on October 14, 2021.
(2) Unit 2 high pressure turbine enclosure heavy lift, station battery testing, and safety significant pre-outage ventilation lineup changes on October 20, 2021.
(3) Protected system lineup during H bus functional testing on October 26, 2021
(4) Unit 2 elevated risk due to prolonged time at lowered inventory (reactor flange) from head installation error on November 21, 2021.
(5) Unit 2 plant cooldown from Hot Shutdown to Cold Shutdown via steam generator atmospheric PORVs, due to steam leak in main steam valve house on November 29, 2021.
(6) Elevated site risk due to Unit 2 emergency condensate storage tank auxiliary feedwater recirculation line leakage (CR118763 9), on December 10, 2021.

71111.15 - Operability Determinations and Functionality Assessments

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

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

(1) CR1181764, Unit 1, B charging pump motor inboard bearing darkened oil sample on October 7, 2021.
(2) CR1182734, hose house #15 hydrant failure on October 14, 2021.
(3) CR1183214, Number 2 emergency diesel generator nonconforming seismic strap bolting on October 21, 2021.
(4) CR1186371, Beyond design basis spent fuel pit indication uninterruptible power supply battery failure on November 24, 2021.
(5) CR1187639, Unit 2 emergency condensate storage tank auxiliary feedwater recirculation line leakage on December 10, 2021.

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 S am p les)

The inspectors evaluated the following temporary or permanent modifications:

(1) 2-MCM-1150-01, Unit 2 Reactor Disassembly and Reassembly, Revision 45 one time only changes 1, 2, & 3 following human performance event associated with improper installation of reactor vessel head studs on November 21, 2021.
(2) ETE-SU-2021-0072 & CR1186299, Classification of piping between main steam trip and non-return valves on November 18, 2021.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sam ple (IP Section 03.01) (5 Sam ples)

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

(1) Correction of deficiencies from Section XI inspection (WO38103760049) on Novem ber 12, 2021.
(2) Emergency diesel generator 2 operational performance test following outage scope maintenance and start circuit design change (DCN 04 -004 & WO38204218250), on Novem ber 5, 2021.
(3) Repair of steam leak at Unit 2 main steam trip valve steam trap bypass valve seal weld connection (CR1186767) on November 30, 2021.
(4) Operational performance test of Unit 2 turbine driven auxiliary feedwater pump following outage maintenance (WO38204219508), on December 01, 2021.
(5) Unit 1 new regulator installed for pressurizer backup air supply bank 'A' failed during post-maintenance testing (CR1188322 & CR1188455), on December 28, 2021.

71111.20 - Refueling and Other Outage Activities

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

(1) The inspectors evaluated unit 2 refueling outage 2R30 activities from October 24 to Decem ber 2, 2021.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

Main article: IP 71111.22
(1) 2-OPT-EG-001, No. 2 emergency diesel generator monthly start exercise test, on October 19, 2021
(2) 2-OPT-ZZ-001, Engineered safety features actuation with undervoltage and degraded voltage - 2H bus, on October 26, 2021

Inservice Testing (IP Section 03.01) (2 Sam ples)

(1) 1-OPT-RS-001, Containment outside recirculation spray pump flow and leak test (38204209707) on November 9, 2021
(2) 2-OPT-RC-001, 2-RC-PCV-2455C power operated relief valve stroke time testing (CR1186258) on November 24, 2021

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

(1) Reactor Coolant Letdown Containment Penetration (Penetration 28) Type 'C' test and post test valve operability stroke (2-CH-TV-2204B), work order 3820 42199004 on Novem ber 12,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (2 Sam ples)

(1) Unit 1 (October 1, 2020 - September 30, 2021)
(2) Unit 2 (October 1, 2020 - September 30, 2021)

MS06: Emergency AC Power Systems (IP Section 02.05) (2 S am p les)

(1) Unit 1 (October 1, 2018 - September 30, 2021)
(2) Unit 2 (October 1, 2018 - September 30, 2021)

MS07: High Pressure Injection Systems (IP Section 02.06)===

Main article: IP 71151
(1) Unit 1 (October 1, 2018 - September 30, 2021)
(2) Unit 2 (October 1, 2018 - September 30, 2021)

MS08: Heat Rem oval System s (IP Section 02.07) (2 Samples)

(1) Unit 1 (October 1, 2018 - September 30, 2021)
(2) Unit 2 (October 1, 2018 - September 30, 2021)

MS09: Residual Heat Removal Systems (IP Section 02.08) (2 S am p les)

(1) Unit 1 (October 1, 2018 - September 30, 2021)
(2) Unit 2 (October 1, 2018 - September 30, 2021)

MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 1 (October 1, 2018 - September 30, 2021)
(2) Unit 2 (October 1, 2018 - September 30, 2021)

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)

(1) Unit 1 (October 1, 2020 - September 30, 2021)
(2) Unit 2 (October 1, 2020 - September 30, 2021)

BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Sam ples)

(1) Unit 1 (October 1, 2020 - September 30, 2021)
(2) Unit 2 (October 1, 2020 - September 30, 2021)

71152 - Problem Identification and Resolution (PI&R)

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in foreign material exclusion that might be indicative of a more significant safety issue.

INSPECTION RESULTS

Failure to Implement Spent Fuel Pool Instrumentation Equipment Functionality Requirements Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.11] - 71111.15 Systems FIN 05000280,05000281/2021004 - 01 Challenge the Open/Closed Unknown The inspectors identified a finding (FIN) of very low safety significance (Green) associated with Dominion Energys failure to implement Spent Fuel Pool Instrumentation Equipment Functionality requirements established in CM - AA-BDB-102, Beyond Design Basis FL EX Equipment Unavailability Tracking, Revision 12. Specifically, Dominion Energy did not recognize the red alarm light identified on May 29, 2021 could not be due to a spurious user input battery life expiration alarm as the station previously disabled t hese triggers.

Description:

On November 22, 2021, operators on rounds discovered the uninterruptible power supply (UPS) backup battery status -of-charge indicator on 01-FC-CAB-105-2-CABNET, Spent Fuel Pit Wide Range Level Display Cabinet, Channel 2 was blinking red where normally there are five solid green lights (CR1186371). This indicated a reduced state of charge definitively indicating loss of functionality. The red UPS alarm light was also in. This red light was initially identified on rounds on May 29, 2021 (CR1174127). Per the vendor manual the red UPS alarm could be due to battery almost empty, battery not detected, battery replacement required, inadequate remaining backup time, or other user defined parameters. The onboard UPS software records alarms and triggers while continuously monitoring battery charge, health, and function to adapt UPS performance to maximize battery needs.

Spent Fuel Pit Wide Range Level Display Cabinets were installed in accordance with NRC Order EA-12-051 wherein the Commission found that, [d]uring the events in Fukushima, responders were without reliable instrumentation to determine water level in the spent fuel pool. This caused concerns that the pool may have boiled dry, resulting in fuel damage.

Fukushima demonst rated the confusion and misapplication of resources that can result from beyond-design-basis external events when adequate instrumentation is not available. Within this order, the NRC further required, [o]nsite generators used as an alternate power sourc e and replaceable batteries used for instrument channel power shall have sufficient capacity to maintain the level indication function until offsite resource availability is reasonably assured.

The UPS battery backups provide for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of power to the level indication.

Dominion Energy developed CM -AA-BDB-102, Beyond Design Basis FLEX Equipment Unavailability Tracking, Revision 12, to meet the commitments of EA -12- 051. CM-AA-BDB-102, Attachment 2, FLEX Strategy Equipment Unavailability Requirements, Spent Fuel Pool Instrumentation - Equipment Functionality (NEI 12 -02), provides, The primary or back -up instrument channel can be Out -of-Service for testing, maintenance, and/or calibration for up to 90 days provided the other channel is functional. Additionally, compensatory actions must be taken if the instrumentation channel is NOT expected to be restored or is NOT restored within 90 days.

On October 19, 2021, station engineering completed review of the repeat history of 01-FC-CAB-105-02 failures and alarm light indications (CA8504223). This noted that the UPS batteries had recently been replaced on April 13, 2021, following identification of the red alarm light in on rounds on January 17, 2021. CA8504223 further determined that the probable cause of the alarm was the need to adjust the battery replacement date which impacts the alarm set point for user defined time-fo r-battery-life-expiration. At that time, with the red alarm light in for 143 days, the licensee failed to recognize that they had previously turned off the battery life expiration alarm trigger, as described below, and how that impacted the UPS functionality (CA8504223).

The inspectors discovered a series of similar alarms and battery maintenance of both Spent Fuel Pit Wide Range Level Display Cabinet UPS Channels 1 & 2 had been documented in summer of 2019 (CR1125899 & CR1128332). To preclude future spurious red alarm lights, on August 27, 2019, the licensee turned off the user defined time-for-battery-life-expiration alarm trigger, crediting the remaining associated alarms to indicate battery or UPS failure.

Therefore, the alarm first observed on May 29, 2021, could not have been from a user defined battery life expiration trigger. In May, the licensee generated work order 38204242505 to perform corrective maintenance on the degraded UPS. On November 22, 2021, (177 days later) the work order was still in early development.

Corrective Actions: On December 2, 2021, Surry performed corrective maintenance under work order 38204242505 including as found battery voltage measurement and battery replacement. This activity did not include capture of UPS alarm or trigger data.

Corrective Action References: 38204242505, CR1187117

Performance Assessment:

Performance Deficiency: The inspectors found that Dominion Energys failure to implement Spent Fuel Pool Instrumentation Equipment Functionality requirements established in CM -

AA-BDB-102 following identification of red UPS alarm light in on May 29, 2021 until loss of all charge failure on November 22, 2021 was a performance deficiency reasonably within the licensees capability to foresee and prevent.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, since alarm discovery in May 2021 until loss of charge in November 2021, the station mischaracterized the probable cause of the UPS alarm as a spurious user defined battery life expi ration trigger which inspectors identified had been previously defeated. This actual failure condition indicated by the alarm had the potential to challenge spent fuel pit level instrument channel 2 power capacity to maintain the level indication. A function required until offsite resource availability can be reasonably assured as intended under Order EA -12-051 comm itm ents.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At -Power.

This finding is associated with spent fuel pool level instrumentation required by Order EA -12-051.

Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding.

The abnormal indication, red UPS alarm light in, was attributed to an indication problem. Dominion Energy did not thoroughly investigate the prior maintenance activity that disabled the user defined battery life expiration trigger before proceeding.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

Unresolved Item Assessment of the Trip Hook Latch -up of the Unit 2 Turbine 71111.19 (Open) Driven Auxiliary Feedwater Pump URI 05000281/2021004 -02

Description:

On December 1, 2021, the licensee completed post maintenance testing of the Unit 2 turbine-driven auxiliary feedwater (TDAFW) pump train following performance of Auxiliary Feed Pump Terry Turbine Overspeed Trip Device Inspection, Overhaul, and Adjustment. Following the testing, the associated trip throttle valve trip hook latch-up mechanism was left approximately 50% engaged. Operations recognized that they were unable to meet procedural guidance w hich states, in part, Check status of TRIP HOOK - full engagement with LATCH UP LEVER (The surface area contact of the latching faces of the TRIP HOOK and the LATCH UP LEVER should be at least 75%). Operations generated CR1187069 to capture the condition.

The trip hook latch up mechanism holds the latch up lever in the up position. When the turbine trips on overspeed, the trip mechanism pulls the trip hook away from the latch up lever. This causes the trip throttle valve to rapidly close removing steam i nput from the turbine and stopping the pump. Improper engagement of the trip hook latch up mechanism can result in spurious closure of the trip throttle valve causing failures of the pump to start or run when required to respond to an event.

Station engineering reviewed CR1187069 and used engineering judgement to assert that a valve spring within the latch-up linkage mechanism would prevent any further inadvertent motion of the trip hook based upon its applied pressure. Operations used this input to establish the full engagement status check as completed satisfactory.

Station engineering further recommended the engagement be adjusted to 75% during the next quarterly test of the component, noting that the procedural requirement for 75% engagement was incorporated from vendor and other industry design standards.

The inspectors observed that the station had previously updated the design basis to incorporate revised requirements (e.g., 75%) for trip hook latch-up mechanism following a similar event in 2017 (CR1073366). The inspectors identified that this current assessment did not address how the spring pressure allowed the latch mechanism to be less engaged than the design basis acceptance criteria. Furthermore, it did not address the actual amount of engagem ent or its impact on preventing spurious overspeed trips or the potential inability to reset from an overspeed trip, as described in the design basis incorporated following the similar event in 2017.

Given the TDAFW pump trains heat sink safety function a ssociated with a loss of AC power event, the inspectors discussed their concerns with station management. On December 3, 2021, the station ran the TDAFW pump train. When attempting to reset the trip hook latch-up linkage, they, again, observed 50% engageme nt during the full engagement status check.

The station again concluded that Engineering does not have concern that the Unit 2 Terry Turbine will not be able to perform its design function based on observations during 2-OP-FW-002.

The inspectors found that Dominion Energys failure to maintain the unit 2 TDAFW trip hook latch-up mechanism in accordance with test and operating procedures was a performance deficiency reasonably within the licensees ability to foresee and prevent. Specifically, on multiple occasions station engineering used engineering judgement inconsistent with the design basis to justify acceptance of trip hook latch-up mechanism engagement of 50% when greater than 75% engagement was required.

Planned Closure Actions: The licensee has established a corrective action (CA9212266) to engage with the vendor subject matter experts on the applicability of the trip hook latch-up requirements established within the design basis. The licensee believes greater margin exists within the full enga gement criteria described. Upon completion of this activity planned within the first calendar quarter of 2022, the inspectors will review the results of CA9212266 to provide input on the more than minor determination associated with the identified performance deficiency.

Licensee Actions: The station performed troubleshooting on December 9, 2021 under WO#38204281432. This activity discovered lose set screws within the latch up mechanism.

Following tightening, the station performed post maintenance testing. With the linkage properly aligned, Operators attained 100% surface area contact when resetting the trip throttle valve latch-up mechanism.

Corrective Action References: CR1073366, CR1189974, CA9212266

Observation: Trend Review of Foreign Material Exclusion 71152 The inspectors performed a review of potential adverse trends in foreign material exclusion that might be indicative of a more significant safety issue. The inspectors performed interviews and sampled a population of maintenance records, documented inspections,

condition reports, and log entries during the period of January 1, 2021 through December 31, 2021.

Based upon the samples reviewed, the inspectors found that there was an apparent increasing trend in adverse foreign material exclusion events between uni t refueling outages.

However, the station performance improvement team properly identified the need for trend review upon reaching condition and performance monitoring thresholds generating corrective actions consistent with their programs. The inspectors did not identify any findings as a result of this inspection.

EXIT MEETINGS AND DEBRIEFS

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

  • On January 31, 2022, the inspector s presented the integrated inspection results to Johnny Henderson, Director of Safety and Licensing, and other members of the licensee staff.

THIRD PARTY REVIEWS

Inspectors reviewed Management Safety Review Committee reports that were issued during the inspection period.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Corrective Action CR1184906 NRC Identified questions/issues in U2 containment and Aux 11/07/2021

Docum ents

Resulting from

Inspection

Drawings 11548-FP-13C Containment & Recirc Spray System SH.3 Rev 005

Engineering PTR-Commercial Grade Dedication Plan - Diesel Fuel Oil 1

Evaluations 10000032901

PTR-Commercial Grade Dedication Plan - Diesel Fuel Oil 3

10000032901

Miscellaneous Commercial Vendor Programs Commercial Grade Survey of Intertek 06/17/2014

Grade Survey

DS-14-011

Sample ID 2015-Fuel Oil Report of Analysis 08/25/2015

NFLK-000748-

008

Sample ID 2015-Fuel Oil Report of Analysis 08/25/2015

NFLK-000748-

008

Sample ID 2015-Fuel Oil Report of Analysis 11/23/2015

NFLK-000989-

001

Sample ID 2015-Fuel Oil Report of Analysis 11/24/2015

NFLK-000989-

008

Sample ID 2015-Fuel Oil Report of Analysis 11/25/2015

NFLK-000989-

2

Sample ID 2021-Fuel Oil Report of Analysis 08/02/2021

NFLK-000465-

003

Sample ID 2021-Fuel Oil Report of Analysis 08/02/2021

NFLK-000465-

Inspection Type Designation Description or Title Revision or

Procedure Date

005

Sample ID 2021-Fuel Oil Report of Analysis 08/02/2021

NFLK-000465-

013

Procedures 2-OP-RH-001A RHR System Valve Alignment Rev 7

CY-AA-AUX-310 Diesel Fuel Oil Sampling and Testing 13

VPAP-2205 Diesel Fuel Oil Testing Program 6

71111.05 Procedures 0-FS-FP-122 Fire Pre-Plan, Diesel Generator Room Number 2, Elevation 2

feet - 6 inches

0-FS-FP-224 Fire Pre-Plan, Mechanical Equipment Room (MER 5), 4

Elevation 27 feet - 6 inches

71111.08P Corrective Action CA 7665977 Corrective Action (CA) to Engineering to update documents 8/20/19

Docum ents (ER-SU-AUG-101 and AMP) as required

CA 7726026 A new Augmented Plan (ER-SU-AUG-101) should be 111/1/19

created to enhance specifications for

examination requirements based on TB-19-5.

CR-1176685 ASME Section XI IWL Unit 2 Inspection Indications 2021 07/12/2021

CR-1183591 2-RH-P-1B RHR PUMP Boric Acid Evaluation 11/7/21

CR-1183703 Boric Acid found on weld 2-CH-PT-3642 (potential thru-weld 10/25/21

leak, 3/8-inch tubing)

CR-1183717 Boric Acid Evaluation Valve 2-SI-91, IAW Code Case N-566 11/5/21

CR-1183843 Boric Acid Evaluation of 2-RH-19, IAW Code Case N-566-2 11/8/21

PA 7560972 Evaluate/Implement Needed Requirements of MRP 2019-4/4/19

008

Engineering 51-9334439-000 Site Validation of EPRI Qualified Eddy Current Techniques 10/31/21

Evaluations for Surry 2R30

ETE-CEP-2021-Steam Generator Degradation.Assessment, Surry Unit 2 Fall 2021

1011 Refueling Outage 2R30

ETE-SU-2021-Surry Unit-2, MRP-227-1-A Reactor Vessel Internals 11/12/21

0055 Examinations, Engineering Evaluation-Phase 1

Miscellaneous 51-9333405 - 000 Surry Unit 2, 2R30 Steam Generator ECT Examination 9/17/21

Inspection Type Designation Description or Title Revision or

Procedure Date

Inspection Plan

Boric Acid Qualifications 11/10/21

Inspector

PETER05

Docket Nos.: 50- Proposed License Amendment Request One -Time Deferral 4/14/20

280/281, Letter of Surry Unit -2 Steam Generator "B" Inspection

Serial No.20-136

ID No.: 03-Steam Generator Tube - Rolled Tube Plug & Stabilizer Rev. 4

9315755 Installation (ZR) Field Procedure

NDE Inspector Certificate of Personnel Qualification 7/29/21

ID: B0861

NDE Inspector ID Ultrasonic Testing Certification Exp. Date

No.: 3351 1/13/23

NDE Inspector ID Certificate of Personnel Qualification 10/17/21

No.: 57120

NDE Inspector ID Certificate of Personnel Qualification 9/0/21

No.: C5341

NDE Personnel IWE, VT Level II Examiner (ID Initials D.V.R) 1/24/20

Qualification and

Certification

Record

Surry ISI Interval Completion Summary Status Novem ber

Standard Plan 2021

(Baseline)

Standard Code

ASME XI, 2004Ed

Surry Tech Spec One -Time Deferral of Surry Unit-2 Steam Generator B" 5/7/2020

Amendm ent No. Spring 2020 Refueling Outage Inspection (EPID NO. L-

299 2019-LLA-0071)

Tech Spec 6.4-Steam Generator Program 1/28/13

Q

Virginia Electric SURRY POWER STATION, UNIT2, INSERVICE MAY10,

and Power INSPECTION PLAN FOR COMPONENTS AND 2014 - MAY

Company COMPONENT SUPPORTS, FIFTH 10-YEAR INSERVICE 9, 2024

Inspection Type Designation Description or Title Revision or

Procedure Date

(Dominion), Serial INSPECTION INTERVAL

No. 14-

194,Docket No.

50- 281

NDE Reports NDE Report No. UT Exam ination, Com ponent ID No.11548-WMKS-0127J3 / 11/15/21

ISI-2-UT-21-030 6-RC-320 / 1-038, Valve to Elbow Weld

NDE Rpt. No. - PT Results, 02-CH-ICV-3642-VALV, Tubing Fitting, Weld 11/11/21

BOP-PT-21-157 Repair

NDE Rpt. No. ISI-Integral attachment of Component ID 11548 -WMKS-11/5/21

2-PT-21-010 0117A1-1 / 14-RH-101 / H016-2

Report No.: ISl-2-UT Exam ination of Com ponent ID: 11548-WMKS-0117A1 -1 11/8/21

UT-21-019 / 14-RH-101 / 1-03, Elbow to Pipe, RH System

Rpt. No. ISI-2-Magnetic Particle (MT) Examination of Comp ID No. 11548 - 11/15/21

MT-21- 011 WMKS-0103A2-1 / 30-S HP-122 / H03

Summary No. IWE Exam ination, Comp. ID, 11548-IWE/E1.11A, Floor Slab 11/16/21

2.EI.11 A.001 to Metal Liner Interface Area

Procedures 54-131-370-008 Remote Underwater Visual Examination of PWR Reactor 8/27/21

Pressure Vessel Internals in Accordance with MRP 227 &

28

Doc. No.: 03-Field Procedure for Performing CRGT Guide Card Wear Rev. 003

259968 Measurements

ER-AA-NDE-UT-Ultrasonic Examination of Austenitic Piping Welds in Rev. 8

2 Accordance with ASME

Section XI, Appendix VIII

ER-AA-NDE-VT-IWE Visual Examination Procedure Rev.3

605

ER-AP-BAC-10 Boric Acid Corrosion Control Program Rev. 14

ER-AP-BAC-101 Boric Acid Corrosion Control Program (BACCP) Inspections Rev. 14

Inspection Type Designation Description or Title Revision or

Procedure Date

ER-AP-BAC-102 Boric Acid Corrosion Control Program (BACCP) Evaluations Rev. 16

ER-SU-AUG-101 Surry Augmented Inspection Program Rev. 19

SRY-SGPMS-002 SURRY SITE SPECIFIC EDDY CURRENT ANALYSIS Rev. 30

GUIDELINES

Self-A sse ssm en t s PI-AA-100-1004, Review of the Steam Generator Program ????

Attachm ent 2,

PIR-1030006

Assessment No. Provide a review of the Reactor Coolant System, Material Surry, June

PIR1119200 Degradation Management Program 19-22, 2017

PIR 1079417 Fleet Inservice Inspection Program Formal Self-Assessment 1/24/18

71111.11Q Miscellaneous Emergency Preparedness Drill Guide 10/14/2021

Procedures 2-GOP-2.2 Unit Shutdown, Less than 30% to Hot Shutdown 52

2-OP-RH-001 Residual Heat Removal Operations 30

71111.12 Corrective Action CA8816961

Docum ents CR1184906

Resulting from

Inspection

71111.13 Miscellaneous Unit 2 Outage 10/20/2021

Risk Assessment

Unit 2 Outage 10/26/2021

Risk Assessment

Unit 2 Outage 11/21/2021

Risk Assessment

Unit 2 Outage 11/29/2021

Risk Assessment

71111.19 Procedures 0-MCM-0113-02 Auxiliary Feedwater Pump Inspection and Maintenance Rev 21

0-MCM-1403-01 Terry Turbine Overhaul, 1-FW-T-2 and 2-FW-T-2 Rev 28

0-MCM-1403-01 TERRY TURBINE OVERHAUL, 1-FW-T-2 AND 2-FW-T-2 28

0-MCM-1403-02 AUXILIARY FEED PUMP TERRY TURBINE OVERSPEED 15

TRIP DEVICE INSPECTION, OVERHAUL, AND

ADJUSTMENT

2-OPT-EG-009 Number 2 Emergency Diesel Generator Major Maintenance Rev 64

Operability Test

2-OPT-FW-003 Turbine Driven Auxiliary Feedwater Pump 2-FW-P-2 Rev 70

Inspection Type Designation Description or Title Revision or

Procedure Date

2-OPT-FW-007 Turbine Driven AFW Pump Steam Supply Line Check Valve Rev 7

test

Work Orders 38204218250 547 Day Freq. PT: EDG 2 Major Maintenance Operability 11/05/2021

Test

71111.20 Miscellaneous S2C31 Full Core Revision 0

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

2-GOP-2.2 Unit Shutdown, Less than 30% to Hot Shutdown 52

2-MCM-1150-01 Unit 2 Reactor Vessel Disassembly and Reassembly 45

2-OP-RC-004 Draining the Reactor Coolant System to Reactor Flange 44

Level

2-OP-RH-001 Residual Heat Removal Operations 30

71111.22 Procedures 2-OPT-CT-201 Containment Isolation Valve Local Leak Rate Testing (Type Rev 23

C Containment Testing)

2-OPT-EG-001 Number 2 Emergency Diesel Generator Monthly Start 84

Exercise Test

Work Orders 38204209707 Perform 1-OPT-RS-001, Outside recirculation spray pump 05/03/2021

flow and leak test on November 9, 2021

204219904 547 Day Freq. PT: Cont. Isol. Vlv. Local Leak Rate test

(Type C) - OC-23B 2-OPT-CT-201

71151 Miscellaneous Consolidated Data Entry Derivation and Margin Reports for

Surry Power Station Mitigating System Performance Index

Performance Indicators 2018 through 2021.

71152 Corrective Action CR1164749, Foreign Material Exclusion condition reports

Docum ents CR1163901,

CR1163867,

CR1171442,

CR1170791,

CR1171369,

CR1171899,

CR1172206,

CR1172891,

CR1173717,

CR1171978,

Inspection Type Designation Description or Title Revision or

Procedure Date

CR1173624,

CR1173938,

CR1172050,

CR1172361,

CR1184233,

CR1185749,

CR1186575,

CR1186578,

CR1184593,

CR1186059,

CR1186207,

CR1185965,

CR1185620,

CR1185053,

CR1184640,

CR1186267,

CR1186310,

CR1184544,

CR1185486,

CR1185002,

CR1188042,

CR1188395

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