IR 05000280/2018003: Difference between revisions

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==REACTOR SAFETY==
==REACTOR SAFETY==


==71111.01 - Adverse Weather Protection==
==71111.01 - Adverse Weather Protection Impending Severe Weather==
 
===Impending Severe Weather===
{{IP sample|IP=IP 71111.01|count=1}}
{{IP sample|IP=IP 71111.01|count=1}}


The inspectors evaluated readiness for impending adverse weather conditions for hurricane Florence on September 10-13, 2018.
The inspectors evaluated readiness for impending adverse weather conditions for hurricane Florence on September 10-13, 2018.


==71111.04 - Equipment Alignment==
==71111.04 - Equipment Alignment Partial Walkdown==
 
===Partial Walkdown===
{{IP sample|IP=IP 71111.04|count=3}}
{{IP sample|IP=IP 71111.04|count=3}}


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: (3) A, B, and C main control room (MCR) chiller service water (SW) trains following high flow SW system flushing, on September 13, 2018
: (3) A, B, and C main control room (MCR) chiller service water (SW) trains following high flow SW system flushing, on September 13, 2018


==71111.05AQ - Fire Protection Annual/Quarterly==
==71111.05AQ - Fire Protection Annual/Quarterly Quarterly Inspection==
 
===Quarterly Inspection===
{{IP sample|IP=IP 71111.05AQ|count=5}}
{{IP sample|IP=IP 71111.05AQ|count=5}}


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: (5) Unit 1 Emergency Switchgear Room
: (5) Unit 1 Emergency Switchgear Room


==71111.06 - Flood Protection Measures==
==71111.06 - Flood Protection Measures Cables==
 
===Cables===
{{IP sample|IP=IP 71111.06|count=1}}
{{IP sample|IP=IP 71111.06|count=1}}


Line 99: Line 91:
: (1) Cable vaults 1-EP-MH-1, 1-EP-MH-2, 1-EP-MH-3 on September 26, 2018
: (1) Cable vaults 1-EP-MH-1, 1-EP-MH-2, 1-EP-MH-3 on September 26, 2018


==71111.07 - Heat Sink Performance==
==71111.07 - Heat Sink Performance Heat Sink==
 
===Heat Sink===
{{IP sample|IP=IP 71111.07|count=1}}
{{IP sample|IP=IP 71111.07|count=1}}


The inspectors evaluated Unit 1 B and C recirculation spray heat exchangers performance on August 1, 2018.
The inspectors evaluated Unit 1 B and C recirculation spray heat exchangers performance on August 1, 2018.


==71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance==
==71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification==
 
===Operator Requalification===
{{IP sample|IP=IP 71111.11|count=1}}
{{IP sample|IP=IP 71111.11|count=1}}


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The inspectors observed and evaluated licensed operator performance in the MCR during 1/2-PT-41.1, Component Cooling Pump Performance Test, on July 17, 2018; 1-OPT-RX-005, Control Rod Assembly Partial Movement, on August 31, 2018; Unit 2 Channel 3 Process Performance Tests, on September 18, 2018; and 1-OPT-SI-005, Low Head Safety Injection Pump Performance Test, on September 19, 2018.
The inspectors observed and evaluated licensed operator performance in the MCR during 1/2-PT-41.1, Component Cooling Pump Performance Test, on July 17, 2018; 1-OPT-RX-005, Control Rod Assembly Partial Movement, on August 31, 2018; Unit 2 Channel 3 Process Performance Tests, on September 18, 2018; and 1-OPT-SI-005, Low Head Safety Injection Pump Performance Test, on September 19, 2018.


==71111.12 - Maintenance Effectiveness==
==71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness==
 
===Routine Maintenance Effectiveness===
{{IP sample|IP=IP 71111.12|count=3}}
{{IP sample|IP=IP 71111.12|count=3}}


Line 129: Line 115:


==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
 
{{IP sample|IP=IP 71111.13|count=3}}
==={{IP sample|IP=IP 71111.13|count=3}}


The inspectors evaluated the risk assessments for the following planned and emergent work activities:
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
Line 158: Line 143:
: (4) 2-OPT-CH-001, Charging Pump Operability and Performance Test for 2-CH-P-1A, following the Unit 2 A CH pump motor overhaul, on August 29, 2018
: (4) 2-OPT-CH-001, Charging Pump Operability and Performance Test for 2-CH-P-1A, following the Unit 2 A CH pump motor overhaul, on August 29, 2018


==71111.22 - Surveillance Testing==
==71111.22 - Surveillance Testing The inspectors evaluated the following surveillance test:
 
Routine==
The inspectors evaluated the following surveillance test:
{{IP sample|IP=IP 71111.22|count=1}}
Routine===
{{IP sample|IP=IP 71111.13|count=1}}
: (1) 0-OSP-VS-012, High Flow Flush of SW Strainers and Piping in mechanical equipment room (MER) 3 and MER 4, Revision 6, on August 3, 2018
: (1) 0-OSP-VS-012, High Flow Flush of SW Strainers and Piping in mechanical equipment room (MER) 3 and MER 4, Revision 6, on August 3, 2018


==71114.06 - Drill Evaluation==
==71114.06 - Drill Evaluation Emergency Planning (EP) Drill==
 
===Emergency Planning (EP) Drill===
{{IP sample|IP=IP 71114.06|count=1}}
{{IP sample|IP=IP 71114.06|count=1}}


Line 181: Line 162:
: (4) Unit 2 Emergency AC Power MSPI
: (4) Unit 2 Emergency AC Power MSPI


==71152 - Problem Identification and Resolution==
==71152 - Problem Identification and Resolution Semiannual Trend Review==
 
===Semiannual Trend Review===
{{IP sample|IP=IP 71152|count=1}}
{{IP sample|IP=IP 71152|count=1}}


Line 197: Line 176:
Observation
Observation


==71152 - Semi-Annual==
==71152 - Semi-Annual
 
                                                                                ==
Trend Review The inspectors performed a review of the licensees corrective action program documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment and corrective maintenance issues, but also considered the results of daily inspector corrective action program item screening.
Trend Review The inspectors performed a review of the licensees corrective action program documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment and corrective maintenance issues, but also considered the results of daily inspector corrective action program item screening.


Line 207: Line 186:
Observation
Observation


==71152 - Annual Follow-==
==71152 - Annual Follow-
 
                                                                          ==
up of Selected Issues The inspectors performed a detailed review of the corrective action from the following condition reports:
up of Selected Issues The inspectors performed a detailed review of the corrective action from the following condition reports:
* CR 573193, Trash Rack Blockage at Unit 1 B High Level Trash Rack
* CR 573193, Trash Rack Blockage at Unit 1 B High Level Trash Rack
Line 215: Line 194:
Observation
Observation


==71152 - Annual Follow-==
==71152 - Annual Follow-
 
                                                                          ==
up of Selected Issues The inspectors performed a detailed review of the corrective action from the following condition reports:
up of Selected Issues The inspectors performed a detailed review of the corrective action from the following condition reports:
* CR 1042126, While Performing 2-PT-8.1, Reactor Trip Breaker Failed to Open
* CR 1042126, While Performing 2-PT-8.1, Reactor Trip Breaker Failed to Open

Revision as of 12:21, 15 November 2019

Nuclear Regulatory Commission Integrated Inspection Report 05000280/2018003 and 05000281/2018003
ML18306A957
Person / Time
Site: Surry  Dominion icon.png
Issue date: 10/26/2018
From: David Hardage
NRC/RGN-II/DRP/RPB4
To: Stoddard D
Virginia Electric & Power Co (VEPCO)
References
IR 2018003
Download: ML18306A957 (18)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ber 26, 2018

SUBJECT:

SURRY POWER STATION - NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 05000280/2018003 AND 05000281/2018003

Dear Mr. Stoddard:

On September 30, 2018, the United States Nuclear Regulatory Commission (NRC) completed an inspection at your Surry Power Station, Units 1 and 2. On October 17, 2018, the NRC inspectors discussed the results of this inspection with Mr. Roy Simmons, and other members of your staff. The results of this inspection are documented in the enclosed inspection report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy.

If you contest the violation or significance of this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Surry Power Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at the 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

David H. Hardage, Acting Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos.: 50-280, 50-281 License Nos.: DPR-32, DPR-37

Enclosure:

IR 05000280/2018003, 05000281/2018003

Inspection Report

Docket Numbers: 50-280, 50-281 License Numbers: DPR-32, DPR-37 Report Numbers: 05000280/2018003 and 05000281/2018003 Enterprise Identifier: I-2018-003-0048 Licensee: Virginia Electric and Power Company (VEPCO)

Facility: Surry Power Station, Units 1 and 2 Location: 5850 Hog Island Road Surry, VA 23883 Inspection Dates: July 1, 2018 - September 30, 2018 Inspectors: P. McKenna, Senior Resident Inspector C. Read, Resident Inspector Approved By: David H. Hardage, Acting Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance by conducting a quarterly integrated inspection at Surry Power Station, Units 1 and 2, 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. NRC and self-revealed findings, violations, and additional items are summarized in the table below.

List of Findings and Violations Failure to Control a Modification on the Containment Spray System Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV H.3 - Change 71111.15 05000280/2018003-01 Management Closed An NRC-identified Green non-cited violation (NCV) of 10 CFR Part 50, Appendix B,

Criterion III, Design Control, was identified for the licensees failure to control the modification for installation of a drain line on the Unit 1 A Containment Spray (CS) pump bearing housing. This resulted in the drain line being blocked by boric acid and inoperability of the Unit 1 A CS pump.

PLANT STATUS

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

Unit 2 operated at or near rated thermal power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection Impending Severe Weather

The inspectors evaluated readiness for impending adverse weather conditions for hurricane Florence on September 10-13, 2018.

71111.04 - Equipment Alignment Partial Walkdown

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

(1) Unit 1 and Unit 2 high head safety injection flow paths, on August 16, 2018
(2) Numbers 2 and 3 emergency diesel generators (EDGs) during number 1 EDG quarterly performance testing, on August 20, 2018
(3) A, B, and C main control room (MCR) chiller service water (SW) trains following high flow SW system flushing, on September 13, 2018

71111.05AQ - Fire Protection Annual/Quarterly Quarterly Inspection

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Black Battery Building
(2) Units 1 and 2 Relay Rooms
(3) Number 3 EDG Room
(4) Unit 1 Cable Vault and Tunnel
(5) Unit 1 Emergency Switchgear Room

71111.06 - Flood Protection Measures Cables

The inspectors evaluated cable submergence protection in:

(1) Cable vaults 1-EP-MH-1, 1-EP-MH-2, 1-EP-MH-3 on September 26, 2018

71111.07 - Heat Sink Performance Heat Sink

The inspectors evaluated Unit 1 B and C recirculation spray heat exchangers performance on August 1, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

The inspectors observed and evaluated a simulator scenario involving a steam generator faulted to containment and a failure of the HiHi consequence limiting safeguard signal, coincident with a failure of a CS pump, with a Site Area Emergency declaration on

===September 4, 2018.

Operator Performance (1 Sample)===

The inspectors observed and evaluated licensed operator performance in the MCR during 1/2-PT-41.1, Component Cooling Pump Performance Test, on July 17, 2018; 1-OPT-RX-005, Control Rod Assembly Partial Movement, on August 31, 2018; Unit 2 Channel 3 Process Performance Tests, on September 18, 2018; and 1-OPT-SI-005, Low Head Safety Injection Pump Performance Test, on September 19, 2018.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Unit 1 circulating water (CW) and SW piping carbon fiber reinforced polymer repair
(2) Containment air coolers and chilled component cooling water
(3) Preventative maintenance critical component classification reduction

71111.13 - Maintenance Risk Assessments and Emergent Work Control

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Units 1 and 2 risk while the A emergency service water (ESW) pump was declared inoperable with the Unit 2 A Charging (CH) pump, the B component cooling (CC)pump, and the D MCR chiller out of service for planned maintenance, on July 16, 2018
(2) Units 1 and 2 risk while the B ESW pump, the Unit 1 B CH service water pump, the Unit 2 A CH pump, the B CC pump, and the A spent fuel pump were all out of service for planned maintenance, on August 2, 2018
(3) Units 1 and 2 risk while the A ESW pump was out of service on September 11, 2018, and the C ESW pump was out of service on September 12, 2018, for suction bowl cleaning while the site was in its severe weather procedure for hurricane Florence preparations, on September 11 and 12, 2018

71111.15 - Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) CR1095443, 1-RS-P-2B, B outside recirculation spray (OSRS) pump motor inductance issue, on August 1, 2018
(2) CR1100006, 2-SD-TV-206, Unit 2 high pressure heater drain tank level control valve (LCV) low air pressure trip valve air leak, on August 28, 2018
(3) CR1098928, Unit 1 "A" CS pump water in bearing oil, on August 15, 2018
(4) Tank-o-meter hydrostatic level instrumentation use for ESW pump fuel oil tank level measurements, on August 29, 2018
(5) CR1103701, Rainwater entering number 1 EDG room while EDG was running, on August 22, 2018
(6) CR1104058, CR1103627, and CR1103219 inoperability of emergency service water pumps A, B and C on successive weeks, on September 24, 2018
(7) Annual Sample on Operator Work Arounds, on September 14, 2018

71111.19 - Post Maintenance Testing

The inspectors evaluated the following post maintenance tests:

(1) 0-OPT-EG-007, EDG 3 Starting Air Refueling Interval Test, of the number 3 EDGs number 2 starting air compressor following head gasket replacement, on June 28, 2018
(2) 1-IPT-CC-CW-L-102, Intake Canal Level Probe 1-CW-LS-102 Time Response Test and Channel Calibration, after replacement of the failed of 1-CW-LS-102 canal level probe, on July 23, 2018
(3) 0-OPT-SW-001, Emergency Service Water Pump 1-SW-P-1A, following the replacement of the bearing oil cooler connection for the A ESW pump, on August 13, 2018
(4) 2-OPT-CH-001, Charging Pump Operability and Performance Test for 2-CH-P-1A, following the Unit 2 A CH pump motor overhaul, on August 29, 2018

==71111.22 - Surveillance Testing The inspectors evaluated the following surveillance test:

Routine==

(1) 0-OSP-VS-012, High Flow Flush of SW Strainers and Piping in mechanical equipment room (MER) 3 and MER 4, Revision 6, on August 3, 2018

71114.06 - Drill Evaluation Emergency Planning (EP) Drill

The inspectors evaluated a licensee EP drill involving a seismic event that caused fuel damage and a reactor coolant system leak, which became a large break loss of coolant accident with a potential containment barrier loss, resulting in a General Emergency declaration, on September 25,

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below for the period from July 1, 2017, through June 30, 2018.

(1) Unit 1 Auxiliary Feedwater MSPI
(2) Unit 2 Auxiliary Feedwater MSPI
(3) Unit 1 Emergency AC Power MSPI
(4) Unit 2 Emergency AC Power MSPI

71152 - Problem Identification and Resolution Semiannual Trend Review

The inspectors reviewed the licensees corrective action program for the period of January -

June 2018 for trends that might be indicative of a more significant safety issue.

Annual Follow-up of Selected Issues (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) 2015 and 2018 Intake Canal Fish Kill which clogged the high level intake structure (HLIS) (CRs 573193, 1087253)
(2) Reactor trip breaker testing issues (CRs 1042126, 1045354, 1077211)

INSPECTION RESULTS

Observation

==71152 - Semi-Annual

==

Trend Review The inspectors performed a review of the licensees corrective action program documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment and corrective maintenance issues, but also considered the results of daily inspector corrective action program item screening.

The review included issues documented outside the normal correction action program in system health reports, corrective maintenance work orders, component status reports, site monthly meeting reports, and maintenance rule assessments. The inspectors review nominally considered the six-month period of January through June 2018, although some examples extended beyond those dates when the scope of the trend warranted.

The inspectors compared and contrasted their results with the results contained in the licensees latest condition report trending/human performance trends. Corrective actions associated with a sample of the issues identified in the licensees trend report were reviewed for adequacy. In general, the licensee has identified trends and has addressed the trends with their corrective action program. The inspectors did note that there has been a significant increase in control rod position indication CRs, especially on Unit 1 after reactor startup from the May refueling outage. The licensee has taken corrective action to correct the issues identified in these CRs.

Observation

==71152 - Annual Follow-

==

up of Selected Issues The inspectors performed a detailed review of the corrective action from the following condition reports:

  • CR 573193, Trash Rack Blockage at Unit 1 B High Level Trash Rack
  • CR 1087253, Initiated 0-AP-23.00 on Unit 2 Due to High Level Intake Structure Flooding The inspectors chose this sample because a blockage of the Unit 1 HLIS occurred in March 2015, due to a severe cold weather fish kill in the intake canal. This same issue occurred again in January 2018 on Unit 2. The corrective action from the March 2015 issue consisted of procedural changes to the stations Severe Weather Preparation procedure, 0-OP-ZZ-21, in order to mitigate bio-fouling of the Unit 1 and Unit 2 HLIS during severe cold weather conditions. Since the issue occurred again in January 2018, the inspectors determined that the corrective actions were not sufficient from the 2015 issue, but did not rise to the level of a more than minor performance deficiency. The licensee has planned corrective actions to address the potential fish kill during severe cold weather.

Observation

==71152 - Annual Follow-

==

up of Selected Issues The inspectors performed a detailed review of the corrective action from the following condition reports:

  • CR 1042126, While Performing 2-PT-8.1, Reactor Trip Breaker Failed to Open
  • CR 1045354, Unit 1 A Reactor Trip Bypass Breaker Opened Unexpectedly during 1-PT-8.1
  • CR 1077211, Sat but degrading Unit 2 B Reactor Trip Breaker Opening Time The inspectors chose this sample because of the multiple issues with reactor trip breakers and reactor trip bypass breakers over the past two years. The inspectors determined that the corrective actions developed as a result of the condition reports were reasonably commensurate with the safety significance of the reactor trip breakers.

Failure to Control a Modification of the Containment Spray System Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green NCV H.3 - Change 71111.15 Systems05000280/2018003-01 Management Closed An NRC-identified Green NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, was identified for the licensees failure to control the modification for installation of a drain line on the Unit 1 A CS pump bearing housing. This resulted in the drain line being blocked by boric acid and inoperability of the Unit 1 A CS pump.

Description:

On June 1, 2018, during a performance test and oil sample of the Unit 1 A CS pump (1-CS-P-1A), the licensee discovered water in the oil sample and immediately declared the pump inoperable. Inspection of the pump outboard bearing drain line revealed that boron had clogged the drain line between the outboard bearing housing and a nearby floor drain.

Licensee inspection of the drain line also revealed that the drain line piping was not sloped properly, which allowed borated water to stand inside the piping. During the pump run, the clogged drain line allowed water to fill the bearing bracket and enter into the outboard bearing housing via the oil seal.

The licensee scheduled an apparent cause evaluation (ACE), but it was cancelled following an engineering evaluation that determined the pump was operable. The engineering evaluation determined that approximately 4.5 ounces of water was in the 64-ounce pump outboard bearing housing. The evaluation used the dimensions of the housing and the slinger ring design to conclude that the containment spray pump would have met its 4-hour mission time.

The inspectors questioned the licensee in order to determine if the polyvinyl chloride (PVC)drain line had been installed using an appropriate approved process. The licensee determined that, prior to 2000, a Fix-it-Now (FIN) team installed the PVC drain to divert seal leakage from the bearing bracket to a nearby floor drain. No design modification, engineering evaluation, as-built inspection, or preventative maintenance of the installed piping was found.

Surry procedure WM-AA-100, Work Management, states, in part, that the System Engineer is responsible for maintaining cognizance of planned maintenance activities being performed on their systems and reviewing work orders on permanent plant structures, equipment, and components for important issues, license renewal reliability concerns, potential operability or Maintenance Rule (a)(4) concerns. The PVC drain lines added to the Unit 1 A CS pump were not properly evaluated for impacts to the CS pump, were not installed with the proper slope, and had no preventative maintenance to flush borated water from the line following a pump run. The combination of these issues resulted in the PVC drain lines being blocked by boric acid, backing up water in the bearing bracket, and water entering the pump oil through the bearing seal.

Corrective Actions: The licensees immediate corrective action was to declare the A CS pump inoperable. The licensee restored the pump by cutting the PVC drain line and installing a catch bag to divert any leakage to a nearby drain. The oil was replaced, the bearing was flushed, and the pump passed the post maintenance test.

Corrective Action Reference: CR1098928

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensees failure to control modifications to safety-related components was a performance deficiency (PD) that was within the licensees ability to foresee and correct. Specifically, the addition of the drain line to the Unit 1 A CS pump caused the pump to be susceptible to water intrusion into the oil through the bearing seal, and this change was not evaluated or implemented using an approved design change process.

Screening: The inspectors determined that the PD was more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Specifically, the change resulted in water in the oil of the Unit 1 A CS pump, and inoperability of the Unit 1 A CS pump.

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter (IMC) 0609.04, Initial Characterization of Findings, Table 2, dated October 7, 2016; the finding was determined to adversely affect the Mitigating Systems Cornerstone. The inspectors screened the finding using IMC 0609, Appendix A, Significance Determination Process (SDP) for Findings at-Power, Exhibit 2 dated June 19, 2012, and determined that it screened as Green because the PD affected the design or qualification of the CS system.

Cross-cutting Aspect: This finding has a cross-cutting aspect in the change management component of the human performance area, H.3, because the licensee failed to follow a systematic process for evaluating and implementing the change. Specifically, the licensee failed to analyze the potential of boric acid blocking the drain line and allowing water intrusion into the pump oil. It is considered present performance because the licensee had opportunity to document and correct the deficient drain line after observing quarterly testing of the Unit 1 A CS pump.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion III requires, in part, that design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the applicant designates another responsible organization.

Contrary to the above, prior to 2000 and continuing to June 1, 2018, the licensee failed to control the design change for installation of a drain line on the Unit 1 A CS pump bearing housing.

Enforcement Action: This violation is being treated as a Non-Cited Violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

  • On October 17, 2018, the inspectors presented the quarterly resident inspector inspection results to Mr. Roy Simmons, and other members of the licensee staff.

DOCUMENTS REVIEWED

IP 71111.01: Adverse Weather Protection

Procedures

0-AP-37.01, Abnormal Environment Conditions, Rev. 71

0-OP-ZZ-021, Severe Weather Preparation, Rev. 20

IP 71111.04: Equipment Alignment

Procedures

1-OP-EG-001A, EDG 1 System Alignment, Rev. 14

1-OP-SI-001A, Safety Injection System Alignment, Rev. 19

2-OP-SI-001A, Safety Injection System Alignment, Rev. 15

OP-49.1B, Service Water System - CR Chillers and Supply Strainers Alignment, Rev. 38

Condition Reports (*NRC Identified)

  • 1100867 *1100865 *1102900 *1102906 *1103111 *1103701
  • 103772 *1103907 *1103910 *1103911 *1103915 *1103916
  • 1104325 *1105199

IP 71111.05: Fire Protection

Procedures

0-FS-FP-123, Diesel Generator Room Number 3 Elevation 27 Feet - 6 Inches, Rev. 2

0-FS-FP-166, Black Battery Room Elevation 27 Feet- 6 Inches, Rev. 2

1-FS-FP-101, Unit 1 Cable Vault Penetration Area Elevation 15 Feet - 0 Inches, Rev. 3

1-FS-FP-102, Unit 1 Cable Vault Tunnel Elevation 9 Feet - 6 Inches and 15 Feet - 0 Inches,

Rev. 3

1-FS-FP-103, Unit 1 Upper Cable Vault Penetration Area Elevation 35 Feet - 6 Inches, Rev. 3

1-FS-FP-107, Unit 1 Emergency Switchgear Room Elevation 9 Feet - 6 Inches, Rev. 3

1-FS-FP-108, Unit 1 Relay Room Elevation 9 Feet - 6 Inches, Rev. 3

1-LPT-FP-018, Emergency Switchgear Room Halon System Cylinder Pressure and Weight

Test, Rev. 14

2-FS-FP-108, Unit 2 Relay Room Elevation 9 Feet - 6 Inches, Rev. 3

IP 71111.06: Flood Protection

Procedures

0-MCM-1207-03, Inspection of Electrical Cable Vaults with Safety Related Cables, Rev. 3

Work Orders

38103738886

IP 71111.07: Heat Sink Performance

Procedures

0-MCM-0802-01, Recirculation Spray Heat Exchanger Inspection and Cleaning, Rev. 11

0-MPM-1901-04, RSHX Service Water Inlet and Outlet Piping Inspection, Rev. 25

1-NPT-SW-009, Inservice Inspection System Pressure Test of Service Water Components

Associated with Recirculation Spray Heat Exchangers 1-RS-E-1B and 1-RS-E-1C, Rev. 5

(OTO-1)

1-OSP-SW-008, SW Flow Test of RSHXs 1-RS-E-1B and 1-RS-E-1C, Rev. 6 (OTO-1)

1-PT-25.2, Testing of Service Water Valves to and from Recirculation Spray Heat Exchangers,

Rev.18

Work Orders

38103629331 38103774506

IP 71111.11: Licensed Operator Requalification Program

Procedures

1-OPT-RX-005, Control Rod Assembly Partial Movement, Rev. 36

1-OPT-SI-005, LHSI Pump Test, Rev. 33

1-PT-41.1, CC Pump Performance Test, Rev. 35

IP 71111.12: Maintenance Effectiveness

Procedures

NO-AA-VEN-204, Supplier Pre-Award Evaluations, Rev. 3

ER-AA-PRS-1003, Equipment Reliability Component Classifications, Rev. 7

Condition Reports

27111 1067643 1084125 1095242 1098113 1098424

1098883 1100733 1100704 1101013 1102283 1102900

Work Orders

204183518 38103066506 38204180600 38204179641

Other Documents

DA-18-075, Simpson, Gumpertz & Heger, Inc. Quality Assurance Program Audit, 06/18/18

DA-18-076, Nuclear Solutions Structural Group Quality Assurance Program Audit, 06/20/18

ETE-SU-2017-0071, Critical Component Reduction (Efficiency Bulletin 16-25), Rev. 0

NEI Efficiency Bulletin 16-25, Critical Component Reduction, Rev. 0

QCE 7279681, Unqualified Vendors on Safety Related Vendor List, 05/25/18

IP 71111.13: Maintenance Risk Assessments and Emergent Work Control

Procedures

NF-AA-PRA-370, Probabilistic Risk Assessment Procedures and Methods: MRule (a)(4) Risk

Monitor Guidance, Rev. 20

WM-AA-20, Risk Assessment of Maintenance Activities, Rev. 2

WM-AA-100, Work Management, Rev. 31

WM-AA-301, Operational Risk Assessment, Rev. 20

Other Documents

EOOS Schedulers Risk Evaluation for Surry Power Station, July 16, 2018

EOOS Schedulers Risk Evaluation for Surry Power Station, August 2, 2018

EOOS Schedulers Risk Evaluation for Surry Power Station, September 11, 2018

EOOS Schedulers Risk Evaluation for Surry Power Station, September 12, 2018

IP 711111.15: Operability Determinations and Functionality Assessments

Procedures

0-ECM-1418-01, Outside Recirculation Spray Pump Motor Maintenance, Rev. 11

CM-AA-12, Configuration Management Change Process, Rev 0

CM-AA-REA-1001, Request for Engineering Assistance, Rev. 4

GMP-015, Raychem Insulation Removal and Installation, Rev. 32

NUS-2030, Specification of Electrical Installation - Surry Power Station - Unit 1 & 2, Rev. 22

OP-AA-100, Conduct of Operations, Rev. 37

OP-AA-1700, Operations Aggregate Impact, Rev. 8

WM-AA-100, Work Management, Rev. 31

Condition Reports

1019445 1061037 1071289 1080268 1086358 1091422

1096802 1098913 1099360 1100006 1100610 1100830

1100869 1101444 1101744 1102730 1103701 1103219

1103627 1104058 1103278 1098928

Work Orders

204181709

Other Documents

ETE-SU-2018-0020, Engineering Instruction for the Repair of Motor Leads for 01-RS-P-2B,

Rev. 0

ODM 1091422, B Main Feed Reg Valve Oscillation, Rev. 0

ODM 1088716, 2-CS-MOV-201 C/D Leakby to Containment Sump, Rev. 0

ODM 1075660, A RCP Lower Motor Bearing Oil Leak, Rev. 0

ODM 1100006, 2-SD-LCV-206 Instrument Air Issues on Valve Operator, Rev. 0

Unit 1 Operations Aggregate Impact List, 09/11/18

Unit 2 Operations Aggregate Impact List, 09/11/18

CM-AA-12, Configuration Management Change Process, Rev. 0

CM-AA-DDC-201, Design Changes, Rev. 0

CM-SU-201, Engineering Limited Scope Modification Process, Rev. 0

DNES-AA-GN-1003, Design Effects and Considerations, Revs. 0 and 19

ER-AA-102, Preventative Maintenance Program, Rev. 11

ER-AA-PRS-1010, Preventative Maintenance Task Basis and Maintenance Strategy, Rev. 10

WM-AA-100, Work Management, Rev. 31

Vendor Technical Manual 38-U002-00001, Tank-o-Meter Installing and Operating Instructions,

Rev. 1

Vendor Technical Manual 38-U002-00002, Installing and Operating Instructions Fueling Type S

Model 3 or 2 Tank-o-Meter Serial No. 45238 for #2 Fuel Oil, Rev. 1

IP 71111.19: Post Maintenance Testing

Procedures

0-OPT-EG-007, EDG 3 Starting Air Refueling Interval Test, Rev. 14

0-OPT-SW-001, Emergency Service Water Pump 1-SW-P-1A, Rev. 63

1-IPT-CC-CW-L-102, Intake Canal Level Probe 1-CW-LS-102 Time Response Test and

Channel Calibration, Rev. 18

2-OPT-CH-001, Charging Pump Operability and Performance Test for 2-CH-P-1A, Rev. 57

Condition Reports

1100676 1103244 1103219

Work Orders

204184364

IP 71111.22: Surveillance Testing

Procedures

0-OSP-VS-012, High Flow Flush of SW Strainers and Piping in MER 3 and MER 4, Rev .6

Work Orders

203885627

IP 71114.06: Emergency Preparedness Drills

Procedures

0-AP-37.00, Seismic Event, Rev. 18

1-AP-10.07, Loss of Unit 1 Power, Rev. 76

1-E-0, Reactor Trip or Safety Injection, Rev. 74

1-E-1, Loss of Reactor or Secondary Coolant, Rev. 45

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 and Local Governments, Rev. 44

Condition Reports

1105880 1105886 1105950 1105969 1105953 1105954

IP 71151: Performance Indicator Verification

Procedures

ER-AA-SPI-101, Implementation of the Consolidated Data Entry (CDE) Reporting for Mitigating

System Performance Index (MSPI), Rev. 0

NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Rev. 7

SU-2014-0082, MSPI Basis Document, Rev. 0

Other Documents

2Q/2018 Performance Indicators - Surry 1 and 2 - Auxiliary Feedwater MSPI, 09/01/18

2Q/2018 Performance Indicators - Surry 1 and 2 - Unit 1 Emergency AC Power MSPI,

09/01/18

Monthly PI Reports with Associated Data, June 2017 to June 2018

IP 71152: Identification and Resolution of Problems

Procedures

0-AP-23.00, Rapid Load Reduction, Rev. 46

0-OP-ZZ-021, Severe Weather Preparation, Rev. 20

1-PT-8.1, Reactor Protection System Logic Testing, Rev. 45

OC-18, Non-Routine Surveillance Log, 10/05/11

Condition Reports

573193 1042126 1045354 1046450 1077211 1078751

1087253 1087254 1087288 1087750 1087760 1089356

1090428 1097300 1097315 1098650 1099344 1093602

1095133 1096721 1097055 1098059 1098732 1099001

1099532 1099648 1099803 1100222 1100330 1100486

1100694 1101895 1102023 1102304 1102050 1103139

1103147 1103150 1087973 1094887 1094889

Other Documents

QCE 298655, Trash Rack Blockage at Unit 1 B High Level Intake Structure, 04/03/15

QCE 3040587, Inadvertent Opening of Unit 1 A Reactor Trip Bypass Breaker, 11/15/16

QCE 3040589, Unexpected Annunciation of 1F-A1, Turbine Trip by Reactor Trip, 10/06/16

REA SU-2018-004, Install Radiant Heaters on the Low and High Level Intake Structures,

01/10/18

Station Performance Meeting Minutes, 02/07/18

Station Performance Improvement Meeting Agenda and Documentation, 07/18/18

15