IR 05000280/2017502

Surry Power Station - NRC Emergency Preparedness Inspection Report 05000280/2017502 and 05000281/2017502 (Public)

ML17230A004
Person / Time
Site:	Surry
Issue date:	08/17/2017
From:	Bonser B R NRC/RGN-II/DRS/PSB1
To:	Stoddard D Virginia Electric & Power Co (VEPCO)
References
IR 2017502
Download: ML17230A004 (12)

Text

August 17, 2017

Mr. Daniel Stoddard Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT: SURRY POWER STATION - U.S. NUCLEAR REGULATORY COMMISSION EMERGENCY PREPAREDNESS INSPECTION REPORT 05000280/2017502 AND 05000281/2017502

Dear Mr. Stoddard:

On July 27, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Surry Power Station, Units 1 and 2. On July 27, 2017, the NRC inspectors, discussed the results of this inspection with Mr. F. Mladen and other members of your staff. The results of this inspection are documented in the enclosed report. The NRC inspectors did not identify any findings or violations of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at https://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."

Sincerely,/RA: Adam Nielson for/ Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket Nos. 50-280 and 50-281 License Nos. DPR-32 and DPR-37

Enclosure:

IR 05000280, 281/2017502

w/Attachment:

Supplemental Information cc: Distribution via Listserve

SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DRS/PSB1 RII:DRS/PSB1 RII:DRS/PSB1RIV:DRS/PSB2 NSIR:DPR/POBRII:DRP/RPB5 RII:DRS/PSB1 SIGNATURE SPS CAF2 JDH9 PJE EPS1 ADM2 AND for BRB1 NAME S. Sanchez C. Fontana J. Hickman P. Elkmann E. Schrader A Masters B. Bonser DATE 8/15/2017 8/16/2017 8/ 15/2017 8/ 15 /2017 8/ 15 /2017 8/17 /2017 8/17 /2017 EMAIL COPY YES NO YES NO YES NO YES NO YES NO YES NO YES NO Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION II Docket Nos: 05000280 and 05000281 License Nos: DPR-32 and DPR-37 Report Nos: 05000280/2017502 and 05000281/2017502 Licensee: Virginia Electric and Power Company (VEPCO) Facility: Surry Power Station, Units 1 and 2 Location: Surry, VA Dates: July 24-27, 2017 Inspectors: Steven Sanchez, Senior Emergency Preparedness Inspector Paul Elkmann, Senior Emergency Preparedness Inspector (R-IV) Christopher Fontana, Emergency Preparedness Inspector John Hickman, Emergency Preparedness Inspector Eric Schrader, Emergency Preparedness Specialist (NSIR) Approved by: Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety

SUMMARY

Inspection Report (IR) 05000280/2017502; 05000281/2017502; 07/24/2017-07/27/2017; Surry Power Station, Units 1 and 2; Emergency Preparedness Exercise and Baseline Inspection. This report covers an announced inspection by four emergency preparedness inspectors and one emergency preparedness specialist. The U.S. Nuclear Regulatory Commission's (NRC) program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6. The NRC inspectors did not identify any findings or violations of more than minor significance.

REPORT DETAILS

REACTOR SAFETY

Cornerstone:

Emergency Preparedness 1EP1 Exercise Evaluation

a. Inspection Scope

The onsite inspection consisted of the following review and assessment:

• The adequacy of the licensee's performance in the biennial exercise, conducted on July 25, 2017, was reviewed and assessed regarding the implementation of the Risk Significant Planning Standards in 10 CFR 50.47(b)(4), (5), (9), and (10); which address emergency classification, offsite notification, radiological assessment, and protective action recommendations, respectively.

• The overall adequacy of the licensee's emergency response facilities were assessed against the licensee's Emergency Plan commitments. The facilities assessed were the Control Room Simulator, Technical Support Center, Operations Support Center, and the local Emergency Operations Facility.

• Other performance areas, such as the emergency response organization's (ERO) recognition of abnormal plant conditions; command and control, intra- and inter- facility communications; prioritization of mitigation activities; utilization of repair and field monitoring teams; interface with offsite agencies; and the overall implementation of the emergency plan and its implementing procedures.

• Past performance issues from NRC inspection reports and Federal Emergency Management Agency (FEMA)/Department of Homeland Security (DHS) exercise reports to determine the effectiveness of corrective actions as demonstrated during this exercise to ensure compliance with 10 CFR 50.47(b)(14).

• The post-exercise critique process and the presentation to the licensee's senior management conducted on July 27, 2017, to evaluate the licensee's self-assessment of its ERO performance during the exercise, and to ensure compliance with 10 CFR Part 50, Appendix E, Subsection IV.F.2.g. The inspectors reviewed various documents, which are listed in the Attachment. The inspectors also attended the FEMA-sponsored public meeting on July 28, 2017. This inspection activity satisfied one inspection sample for the exercise evaluation on a biennial basis.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

Since the last NRC inspection of this program area, one revision to the emergency plan and several revisions to emergency plan implementing procedures had been made. The licensee determined that, in accordance with 10 CFR 50.54(q), the emergency plan continued to meet the requirements of 10 CFR 50.47(b), and Appendix E to 10 CFR Part 50. The inspectors reviewed the revisions, and sampled implementing procedure changes to evaluate potential reductions in the effectiveness of the Plan. As this review was not documented in a Safety Evaluation Report, and does not constitute formal NRC approval of the changes, these changes remain subject to future NRC inspection in their entirety.

The inspection was conducted in accordance with NRC Inspection Procedure (IP) 71114, Attachment 04, Emergency Action Level and Emergency Plan Changes. The applicable planning standards of 10 CFR 50.47(b), and its related requirements in 10 CFR Part 50, Appendix E, were used as reference criteria. The inspectors reviewed various documents, which are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the emergency action level and emergency plan changes on an annual basis.

b. Findings

No findings were identified. 1EP8 Exercise Evaluation - Scenario Review

a. Inspection Scope

Prior to the inspection activity, the inspectors conducted an in-office review of the exercise objectives and scenario submitted to the NRC using IP 71114.08, "Exercise Evaluation - Scenario Review," to determine if the exercise would test major elements of the emergency plan, as required by 10 CFR 50.47(b)(14). The inspectors reviewed various documents, which are listed in the Attachment. This inspection activity satisfied one inspection sample for the exercise evaluation on a biennial basis.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

a. Inspection Scope

The inspectors sampled licensee submittals relative to the performance indicators (PIs) listed below for the period July 1, 2016, through March 31, 2017. To verify the accuracy of the PI data reported during that period, PI definitions and guidance contained in Nuclear Energy Institute 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, was used to confirm the reporting basis for each data element. Emergency Preparedness Cornerstone

• Drill/Exercise Performance (DEP)

• Emergency Response Organization (ERO) Readiness

• Alert and Notification System (ANS) Reliability For the specified review period, the inspectors examined data reported to the NRC, procedural guidance for reporting PI information, and records used by the licensee to identify potential PI occurrences. The inspectors evaluated the accuracy of the PIs for ERO and DEP through review of a sample of drill and event records. The inspectors reviewed selected training records to verify the accuracy of the PI for ERO drill participation for personnel assigned to key positions in the ERO. The inspectors evaluated the accuracy of the PI for ANS reliability through review of a sample of the licensee's records of periodic system tests. The inspectors also interviewed the licensee personnel who were responsible for collecting and evaluating the PI data. Licensee procedures, records, and other documents reviewed within this inspection area are listed in the Attachment. This inspection satisfied three inspection samples for PI verification on an annual basis.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On July 27, 2017, the inspection team presented the inspection results to Mr. F. Mladen and other members of the plant staff. The inspectors confirmed that no proprietary information was provided during the inspection. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

L. Black, Supervisor, Outage & Planning

S. Brawl, Emergency Preparedness Instructor

E. Collins, Manager, Fleet Emergency Preparedness

J. Costello, Fleet Emergency Preparedness Specialist

T. Cuthriell, Licensing Engineer

B. Garber, Manager, Station Licensing

D. Godwin, Manager, Emergency Preparedness

J. Grau, Manager, Nuclear Site Services

J. Henderson, Director, Engineering

R. Herbert, Manager, Design Engineering

J. Holloway, Manager, Site Engineering

L. Jones, Manager, Protection Services

K. Longston, Emergency Preparedness Specialist

F. Mladen, Site Vice President

L. Ragland, Manager, Radiological Protection and Chemistry

B. Rickert, Emergency Preparedness Specialist

J. Rosenberger, Director, Nuclear Safety & Licensing

J. Shell, Assistant Operations Manager

R. Simmons, Plant Manager

T. Swearingen, Emergency Preparedness Specialist

M. True, Emergency Preparedness Specialist

D. Wilson, Manager, Maintenance

LIST OF DOCUMENTS REVIEWED

1EP1 Exercise Evaluation

Procedures

Surry Power Station Emergency Plan, Rev. 63

CPIP-3.1, CERC and CEOF Activation, Rev. 29

CPIP-3.3. Surry LEOF Activation, Rev. 21

CPIP-6.0, LEOF Recovery Manager Guidance, Rev. 14

CPIP-6.2, Radiological Assessment Coordinator, Rev. 15

EP-AA-100, Maintaining Emergency Preparedness, Rev. 6

EP-AA-303, Equipment Important to Emergency Response, Rev. 16

EP-AA-400, Drill and Exercise Program, Rev. 10

EPIP-1.01, Emergency Manager Controlling Procedure, Rev. 58

EPIP-1.03, Response to Alert, Rev. 23

EPIP-1.04, Response to Site Area Emergency, Rev. 23

EPIP-1.05, Response to General Emergency, Rev. 25

EPIP-1.06, Protective Action Recommendations, Rev. 12

EPIP-2.01, Notification of State & Local Governments, Rev. 44

EPIP-2.02, Notification of NRC, Rev. 23

EPIP-3.02, Activation of the Technical Support Center, Rev. 35

EPIP-3.03, Activation of the Operations Support Center, Rev. 22

EPIP-3.05, Augmentation of Emergency Response Organization, Rev. 12

EPIP-4.03, Dose Assessment Team Controlling Procedure, Rev. 20

EPIP-4.07, Protective Measures, Rev. 18

EPIP 4.17, Monitoring of Emergency Response Facilities, Rev. 13

PI-AA-200, Corrective Action, Rev. 33

Records and Data Surry Power Station Emergency Preparedness 2017 Biennial Exercise Scenario, dated 7/25/17

Simulator Control Room, Technical Support Center, Operations Support Center, and the Local Emergency Operations Facility documentation packages (logs, event notification forms, Protective Action Recommendations, Media releases, and Radiological Dose Assessments)

EP-AA-400, Drill and Exercise Program Documents, Attach. 3, Drill/Exercise Objectives,

Rev. 10 0-OP-VS-007, Technical Support Center Ventilation, Rev. 13

0-OCP-EP-200, 4160 Volt Breaker Operations, Rev. 7

Corrective Action Program Documents (Condition Reports)

CR 1010345, Impact of

CA 300179 primary MET tower instrument height changes on atmospheric dispersion factors

CR 1037230, Evaluate required S/G level to ensure fission product scrubbing

CR 1041840, TSC AC unit not working

CR 1045188, TSC AC unit not running

CR 1049158, Emergency Accountability System failed test

CR 1053729, TSC Local Area RM in alarm

CR 1055786, Drill confidential material distributed to key ERO members prior to drill

CR 1059708, Meteorological monitoring panel delta-T indication has failed

CR 1060458, Discrepancy in the minimum staffing requirements of E-plan and

OP-AA-100

CR 1061082, Inaccurate information identified in EPIP 5.09 and the Emergency Personnel

Notification List (EPNL)

CR 1071654, Primary MET tower A/C not working

CR 1072477, Objective 8 met with problems overall

CR 1074320, Some pagers did not activate during the EP Exercise on 7/25/17

CR 1074324, Some batteries appeared dead for ERO radios in OSC

CR 1074327, TSC communication equipment issues

CR 1074331, TSC NRC ENS cordless phone issues

CR 1074336, LEOF instaphone not functioning properly

CR 1074339, ARCOS activation notifications received 12 minutes after declaration of Alert

CR 1074372, RP instrumentation issues during 7/25/17 drill exercise

CR 1074433, Offsite responders arrived at the LEOF after the NEDS communicated habitability requirements

CR 1074436, ERDS data from simulator not visible to NRC

CR 1074468, VDEM observations from LEOF during Exercise

CR 1074472, Question on habitability

CR 1074484, Potential challenges for VDEM with making PADs

CR 1074531, Objective 20 was graded as NOT MET overall for the Exercise

CR 1074534, Lessons learned from Exercise

CR 1074537, 50.72 reporting when in continuous NRC communications (NRC-identified)

CR 1074790, NRC comments for 2017 inspection (NRC-identified)

CR 1074753, Exercise scenario package did not contain demonstration criteria for Semi-Annual

Radiological Monitoring Drill (NRC-identified)

1EP4 Emergency Action Levels and Emergency Plan Changes

Procedures

Surry Power Station (SPS) Emergency Plan, Rev. 62 & 63

EP-AA-101, 10

CFR 50.54(q) Change Evaluation, Rev. 7

EP-AA-102, Revision & Control of Emergency Plan, Emergency Action Levels (Technical Basis and Matrix) & Reference Manual, Rev. 8

EPIP-1.06, Protective Action Recommendations, Rev. 11 & 12

EPIP-4.03, Dose Assessment Team Controlling Procedure, Rev. 19 & 20

EPIP 4.07, Protective Measures, Rev. 17 & 18

Change Packages

SU-14-021, 50.54(q)(3) Screening/Evaluation of

EPIP-2.01 "Notification of State and Local Governments," Rev. 44

SU-14-022, 50.54(q)(3) Screening/Evaluation of

EPIP-2.01 "Notification of State and Local Governments," Rev. 44

SU-16-001, 50.54(q)(3) Screening/Evaluation for

EPIP-1.06 Rev. 12, dated 10/6/16

SU-16-002, 50.54(q)(3) Screening/Evaluation for

EPIP-1.06 Rev. 12, dated 10/6/16

SU-16-003, 50.54(q)(3) Screening/Evaluation for

EPIP-1.06 Rev. 12, dated 10/6/16

SU-16-01, 50.54(q)(3) Screening/Evaluation for EPIP -4.07 Rev. 18, dated 10/6/16

SU-16-05, 50.54(q)(3) Screening/Evaluation for EPIP -4.07 Rev. 18, dated 10/6/16

SU-16-09, 50.54(q)(3) Screening/Evaluation for EPIP -4.07 Rev. 18, dated 10/6/16

SU-16-10, 50.54(q)(3) Screening/Evaluation for EPIP -4.07 Rev. 18, dated 10/6/16

SU-16-11, 50.54(q)(3) Screening/Evaluation for EPIP -4.07 Rev. 18, dated 10/6/16

SU-16-12, 50.54(q)(3) Screening/Evaluation for EPIP -4.07 Rev. 18, dated 10/6/16

SU-16-01, 50.54(q)(3) Screening/Evaluation for SPS Emergency Plan Rev. 63, dated 1/12/17

SU-16-02, 50.54(q)(3) Screening/Evaluation for App. 10.1, Letters of Agreement, dated 1/12/17

SU-16-03, 50.54(q)(3) Screening/Evaluation for Section 6.4.2, dated 1/12/17

SU-16-04, 50.54(q)(3) Screening/Evaluation for Section 6.4.1, dated 1/12/17

SU-16-05, 50.54(q)(3) Screening/Evaluation for Section 6.3.3.3, dated 1/12/17

SU-16-08, 50.54(q)(3) Screening/Evaluation for Title Changes, dated 1/12/17

SU-16-09, 50.54(q)(3) Screening/Evaluation for Sections 6.3.2 & 6.4.1.1, dated 1/12/17

SU-16-10, 50.54(q)(3) Screening/Evaluation for Sections 5.3.1, 5.3.3, 6.1, 6.3.1, 6.4.2, 7.2, &

9.0, dated 1/12/17

SU-16-11, 50.54(q)(3) Screening/Evaluation for Sections 5.2.1.1, 5.2.1.17, 5.2.1.18, 5.3.1,

5.3.1.5, & 7.3.3, dated 1/12/17

SU-16-12, 50.54(q)(3) Screening/Evaluation for Sections 7.2.1.1, dated 1/12/17

Corrective Action Program Documents

CR 1027899, EAL review was not signed by Commonwealth of Virginia representative

CR 1028317, Approver was not qualified to approve 10

CFR 50.54(q) Evaluations

CR 1028735, EP organization changes were made without performing a 50.54(a) evaluation

CR 1031616, EP documentation discrepancies identified

CR 1038104, EP did not follow the SAT process when implementing a change

CR 1061820, Current posted/available versions of

EPIP-4.16 & 4.34 have inconsistent information contained in

EPIP-4.03 & 4.07

CR 1064316, Initiating condition limit for RA1 & RU1a do not match EAL criteria for

RA1.1 &

RU1.1

CR 1074400, Wrong revision numbers referenced in procedure package (NRC-identified)

1EP8 Exercise Evaluation - Scenario Review

Procedures

EP-AA-400, Drill & Exercise Program, Rev. 10

Records and Data Completed Scenario Review Checklist FEMA After Action Report/Improvement Plan, dated 4/27/15

SJUN16FS Management Critique for SPS Full Scale Drill, dated 7/2016

SMAR17FS Management Critique for SPS Full Scale Drill, dated 4/19/17 SDEC16FS Management Critique for SPS Full Scale Drill, dated 1/5/17 SJUN16FS Management Critique for SPS Full Scale Drill, dated 7/20/16

SMAY16FS Management Critique for SPS Full Scale Drill, dated 6/9/16 SFEB16FS Management Critique for SPS Full Scale Drill, dated 3/29/16

Surry 8-Year EAL Matrix

Corrective Action Program Documents

CR 1028053, TSC primary MIDAS computer failed during EP drill training exercise

CR 1028679, Inappropriate controller coaching was observed in two instances in the OSC

CR 1035040, EP baseline inspection NRC observations

CR 1037165, Objective 4, Criterion 3, offsite notification not met

CR 1040589, CERC dose assessment did not adequately compare field data to MIDAS during drill

CR 1042754, SJUN16FS - Objective 20 met with problems

CR 1069966, MIDAS not working properly

4OA1 Performance Indicator Verification

Procedures

EP-AA-103, Emergency Preparedness Performance Indicators, Rev. 4 0-LSP-EW-002, Early Warning System Siren Activation Monitoring, Rev. 11, 12, & 13

PI-AA-200, Corrective Action, Rev. 33

Records and Data DEP opportunities documentation for first, second, third, and fourth quarters 2016; and first quarter 2017 Siren test data for first, second, third, and fourth quarters 2016; and first quarter 2017 Drill and exercise participation records of ERO personnel for first, second, third, and fourth quarters 2016; and first quarter 2017

Corrective Action Program Documents

CR 0569153, Corp ERO availability 2-deep standard not met

CR 1022666, 0-LSP-EW-001 was not completed within grace

CR 1034931, EP ANS KPI values inaccurate for August 2015

CR 1035025, Potential trend for SPS EWS #51

CR 1037901, Minimum qualification guidance for damage control team members in Electrical &

Mechanical maintenance

CR 1043941, SPS EWS Siren Polling Test

CR 1047402, Corporate ERO availability 2-deep minimum standard not met 9/18-10/1/16

CR 1047822, Adverse trend in corporate ERO availability

CR 1055371, Siren 41 did not respond as expected during conduct of 0-LS-EW-007

CR 1061531, Corp ERO availability 2-deep standard not met

CR 1061887, Siren 42 did not activate

CR 1072399, Potential for ERO PAR variability based on

EPIP-4.03, NE-GL-0035S

LIST OF ACRONYMS

USED [[]]

ANS Alert and Notification System

CAP Corrective Action Program

CFR Code of Federal Regulations

CR Condition Reports

DEP Drill and Exercise Performance

DHS Department of Homeland Security

EAL Emergency Action Level

EITER Equipment Important to Emergency Preparedness

EOF Emergency Operations Facility

EP Emergency Preparedness

ERO Emergency Response Organization

FEMA Federal Emergency Management Agency

IP Inspection Procedure

IR Inspection Report

NEI Nuclear Energy Institute

NRC Nuclear Regulatory Commission

OSC Operations Support Center

PI Performance Indicators

ROP Reactor Oversight Program

RSPS Risk Significant Planning Standard

TSC Technical Support Center