ML103020186
| ML103020186 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/29/2010 |
| From: | Gerald Mccoy NRC/RGN-II/DRP/RPB5 |
| To: | Heacock D Virginia Electric & Power Co (VEPCO) |
| References | |
| IR-10-004, IR-10-501 | |
| Download: ML103020186 (30) | |
See also: IR 05000280/2010004
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200
ATLANTA, GEORGIA 30303-1257
October 29, 2010
Mr. David A. Heacock
President and Chief Nuclear Officer
Virginia Electric and Power Company
Innsbrook Technical Center
5000 Dominion Boulevard
Glen Allen, VA 23060-6711
SUBJECT: SURRY POWER STATION - NRC INTEGRATED INSPECTION REPORT
05000280/2010004, 05000281/2010004, 05000280/2010501 and
Dear Mr. Heacock:
On September 30, 2010, the United States Nuclear Regulatory Commission (NRC) completed
an inspection at your Surry Power Station, Units 1 and 2. The enclosed inspection report
documents the inspection results, which were discussed on October 14, 2010, with Mr. Sloane
and other members of your staff.
The inspection examined activities conducted under your licenses as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your
licenses. The inspectors reviewed selected procedures and records, observed activities, and
interviewed personnel.
Based on the results of this inspection, no findings of significance were identified. However,
one licensee-identified violation which was determined to be of very low safety significance is
listed in this report. NRC is treating this violation as a non-cited violation (NCV) consistent with
Section 2.3.2 of the NRC Enforcement Policy because of the very low safety significance of the
violation and because it is entered into your corrective action program. If you contest any 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.
In addition, if you disagree with the characterization of any finding 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 Regional Administrator, Region II; and the NRC Resident Inspector at the
Surry Power Station. The information you provide will be considered in accordance with
Inspection Manual Chapter 0305.
VEPCO 2
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its
enclosure, and your response (if any) will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of the
NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Gerald J. McCoy, Chief
Reactor Projects Branch 5
Division of Reactor Projects
Docket Nos.: 50-280, 50-281
Enclosure: Inspection Report 05000280/2010004, 05000281/2010004, 05000280/2010501 and
w/Attachment: Supplemental Information
cc w/encl. (See page 3)
_________________________ G SUNSI REVIEW COMPLETE
OFFICE RII:DRP RII:DRP RII:DRS RII:DRS RII:DRS RII:DRP
SIGNATURE Via email Via email Via email Via email BRB /RA for/ GJM /RA/
NAME CWelch JNadel JDodson JBeavers LMiller GMcCoy
DATE 10/28/2010 10/27/2010 10/27/2010 10/27/2010 10/27/2010 10/28/2010
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
VEPCO 3
cc w/encl:
Gerald T. Bischof
Site Vice President
Surry Power Station
Virginia Electric and Power Company
Electronic Mail Distribution
B. L. (Sonny) Stanley
Director, Nuclear Safety and Licensing
Virginia Electric and Power Company
Electronic Mail Distribution
Lillian M. Cuoco, Esq.
Senior Counsel
Dominion Resources Services, Inc.
Electronic Mail Distribution
Chris L. Funderburk
Director, Nuclear Licensing & Operations Support
Virginia Electric and Power Company
Electronic Mail Distribution
Ginger L. Alligood
Virginia Electric and Power Company
Electronic Mail Distribution
Virginia State Corporation Commission
Division of Energy Regulation
P.O. Box 1197
Richmond, VA 23209
Attorney General
Supreme Court Building
900 East Main Street
Richmond, VA 23219
Michael M. Cline, Director
Virginia Department of Emergency Services Management
Electronic Mail Distribution
VEPCO 4
Letter to David A. Heacock from Gerald J. McCoy dated October 29, 2010
SUBJECT: SURRY POWER STATION - NRC INTEGRATED INSPECTION REPORT
05000280/2010004, 05000281/2010004, 05000280/2010501 and
Distribution w/encl:
C. Evans, RII
L. Douglas, RII
OE Mail
RIDSNRRDIRS
PUBLIC
RidsNrrPMSurry Resource
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket Nos.: 50-280, 50-281
Report No: 05000280/2010004, 05000281/2010004, 05000280/2010501 and
Licensee: Virginia Electric and Power Company (VEPCO)
Facility: Surry Power Station, Units 1 and 2
Location: 5850 Hog Island Road
Surry, VA 23883
Dates: July 1, 2010 through September 30, 2010
Inspectors: C. Welch, Senior Resident Inspector
J. Nadel, Resident Inspector
L. Miller, Senior EP Inspector, Sections 1EP4, 1EP5, and 4OA5
J. Beavers, EP Inspector, Sections 1EP2, 1EP3, and 4OA1
J. Dodson, Senior Project Engineer
Approved by: Gerald J. McCoy, Chief
Reactor Projects Branch 5
Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000280/2010004, 05000281/2010004, 05000280/2010501, and 05000281/2010501;
07/01/2010 - 09/30/2010; Surry Power Station, Units 1 and 2, Routine Integrated Inspection
Report
The report covered a 3 month period of inspection by resident inspectors and an announced
emergency preparedness inspection by regional specialists. The significance of most findings is
indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). The cross-cutting aspect was determined
using IMC 0310, Components Within The Cross-Cutting Areas. Findings for which the SDP
does not apply may be Green or be assigned a severity level after NRC management review.
The NRCs program for overseeing the safe operation of commercial nuclear power reactors is
described in NUREG-1649, Reactor Oversight Process Revision 4, dated December 2006.
NRC Identified and Self-Revealing Findings
None
Licensee Identified Violations
A violation of very low safety significance that was identified by the licensee has been reviewed
by the inspectors. Corrective actions taken or planned by the licensee have been entered into
the licensees corrective action program. This violation and corrective action tracking numbers
are listed in Section 4OA7 of this report.
Enclosure
REPORT DETAILS
Summary of Plant Status
Unit 1 operated at or near full rated thermal power (RTP) throughout the inspection period.
Unit 2 entered the period at full power. A forced outage was conducted from July 11 - 13 to
repair a non-isolable leak in the circulating water pipe supplying the 2A condenser water box.
The reactor was brought critical following the repair on July 13, however due to a voltage spike
on the main generator during trouble shooting of its voltage regulator, the reactor was shut
down on July 14 to inspect the Unit 2 main and station service transformers. The reactor was
taken critical at 1:21 am on July 16 and the unit was later re-connected to the electrical grid.
Full power was obtained the morning of July 17 and maintained until August 28 when power
was reduced to 84% due to degrading condenser vacuum. The condition was promptly
corrected and full power was restored for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Site Specific Weather
a. Inspection Scope
In response to hurricane Earl, the inspectors reviewed the licensees preparations for
potential severe weather as well as severe weather procedures Operations Check List
(OC) 21, Severe Weather, and 0-AP-37.01, Abnormal Environmental Conditions.
The inspectors walked down site areas which included the electrical switchyard,
emergency diesel generators, alternate AC (AAC) diesel generator, emergency
switchgear rooms, emergency service water pump house, and the turbine, safeguards,
and auxiliary buildings. During the walkdown, the inspectors looked for loose items and
or debris that could become a missile hazard during high winds, verified flooding barriers
were available and / or in place, and verified that the emergency equipment was
available and in the required standby mode. The inspectors were on-site during the
storms passage on Friday, September 3.
b. Findings
No findings were identified.
.2 External Flooding
a. Inspection Scope
The inspectors reviewed the Updated Final Safety Analysis Report and station
procedures for severe weather involving external flooding to evaluate the stations
readiness to cope with external flooding at the intake structure. The inspectors reviewed
Enclosure
4
elevation drawings for the emergency service water (ESW) pump house and walked
down the intake structure to assess the structures water tightness, the readiness of
personnel to respond to hurricane Earl in order to protect the ESW pump house from
flooding, as well as the condition and availability of the buildings removable flood
barriers. The inspectors reviewed the corrective action program to verify the licensee
was identifying weather related problems and entering the issues into the corrective
action program.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Partial Walkdown
a. Inspection Scope
The inspectors performed a partial walk down on the four risk-significant systems
identified below to verify the redundant or diverse train for equipment removed from
service was operable and/or that the system had been properly aligned to perform its
designated safety function following an extended outage. During the walkdown, the
inspectors verified the positions of critical valves, breakers, and control switches by in-
field observation and/or review of the main control board. To determine the correct
configuration to support system operation, the inspectors reviewed applicable operating
procedures, station drawings, the Updated Final Safety Analysis Report, and the
Technical Specifications. During the walkdown, the inspectors attempted to identify any
discrepancies that could impact the function of the system, and, therefore, potentially
increase risk.
- The emergency ventilation A train (1-VS-F-58A) during planned maintenance on the
B train (1-VS-F-58B).
- The motor driven fire pump during testing of the diesel driven fire pump.
- Unit 2 motor driven auxiliary feedwater trains during planned maintenance on the
turbine driven auxiliary feedwater pump.
- The B service water header supply via 1-VS-S-1B during planned maintenance on 1-
VS-S-1A and the associated MER 3 piping.
b. Findings
No findings were identified.
Enclosure
5
.2 Full System Review
a. Inspection Scope
The inspectors performed a full system review and walkdown of the Unit 1 and Unit 2
Main Control Room and Emergency Switchgear Room HVAC systems to verify the
systems were properly aligned and capable of performing their safety function, and to
assess their material condition. During the walkdown, the inspectors verified breaker
positions were in the proper alignment, component labeling was accurate, hangers and
supports were functional, and local indications were accurate. Recent testing history
was also reviewed to verify that standby components were performing within their
design. The plant health report, system drawings, condition reports, the UFSAR, and
Technical Specifications were reviewed and outstanding deficiencies were verified to be
properly classified and not affect system operability and capability to perform its safety
function. The inspectors reviewed the corrective action program to verify equipment
alignment issues were being identified and resolved.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Quarterly Fire Protection Reviews
a. Inspection Scope
The inspectors conducted a defense-in-depth (DID) review for the seven fire areas listed
below by walkdown and review of licensee documents. The reviews were performed to
evaluate the fire protection program operational status and material condition and the
adequacy of: (1) control of transient combustibles and ignition sources; (2) fire detection
and suppression capability; (3) passive fire protection features; (4) compensatory
measures established for out-of-service, degraded or inoperable fire protection
equipment, systems, or features; and (5) procedures, equipment, fire barriers, and
systems so that post-fire capability to safely shutdown the plant is ensured. The
inspectors reviewed the corrective action program to verify fire protection deficiencies
were being identified and properly resolved.
- Fire zone 64, Black Battery House
- Intake Vacuum Priming House
- Fire Zone 52, Unit 1 High Level Intake Control House
- Fire Zone 53, Unit 2 High Level Intake Control House
- Fire zone 48, Screenwell Transformers
- Fire zone Z28B, Intake Structure - Emergency Service Water Pumps
- Fire zone Z28C, Intake Structure - Oil tank Room
Enclosure
6
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
The inspectors reviewed the internal flood protection measures and procedural controls
established to address potential flooding in the Unit 1 and 2 turbine buildings, the
emergency switchgear rooms, and mechanical equipment rooms (MER) 3 and 4 during
ongoing work to repair a non-isolable leak in the 96 inch diameter circulating water
supply line to the Unit 2 main condenser 2A water box and for replacement of the piping
expansion joint 2-SW-REJ-202B located in the 10 inch service water line. The
inspectors conducted a walk down of the affected areas to observe and assess the
condition of the installed flood dikes, floor drain backflow preventers, the sealing of holes
and penetrations between flood areas, the adequacy of water tight doors, and the
operability of flooding alarms and the installed sump pumps. The inspectors reviewed
the corrective action program and verified internal flooding related problems were being
identified and properly addressed.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review
a. Inspection Scope
The inspectors observed an evaluated licensed operator simulator exercise given on
September 14, 2010 using scenario RQ-10.7-SP-1, Rev. 0. The scenario involved both
operational transients and design basis events. The inspector verified that simulator
conditions were consistent with the scenario and reflected the actual plant configuration
(i.e., simulator fidelity). The inspector observed the crews performance to determine
whether the crew met the scenario objectives; accomplished the critical tasks;
demonstrated the ability to take timely action in a safe direction and to prioritize,
interpret, and verify alarms; demonstrated proper use of alarm response, abnormal, and
emergency operating procedures; demonstrated proper command and control;
communicated effectively; and appropriately classified events per the emergency plan.
The inspector observed the evaluators post scenario critique and confirmed items for
improvement were identified and discussed with the operators to further enhance
performance.
b. Findings
No findings were identified.
Enclosure
7
1R12 Maintenance Effectiveness
a. Inspection Scope
For the two equipment issues described in the condition reports listed below, the
inspectors evaluated the effectiveness of the corresponding licensee's preventive and
corrective maintenance. The inspectors performed a detailed review of the problem
history and associated circumstances, evaluated the extent of condition reviews, as
required, and reviewed the generic implications of the equipment and/or work practice
problem(s). Inspectors performed walkdowns of the accessible portions of the system,
performed in-office reviews of procedures and evaluations, and held discussions with
system engineers. The inspectors compared the licensees actions with the
requirements of the Maintenance Rule (10 CFR 50.65), station procedures ER-AA-MRL-
10, Rev. 4, Maintenance Rule Program; and ER-AA-MRL-100, Rev. 1, Implementing
the Maintenance Rule; the Surry Maintenance Rule Scoping and Performance Matrix.
And industry guidance contained in NUMARC 93-01, Rev. 2, Industry Guidance for
Monitoring the Effectiveness of Maintenance at Nuclear Power Plants.
- CR 388265, ESW Pump 1B High Engine Temperature.
- CR 389110, EDG #3 Failed to Start.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors evaluated, as appropriate, for the five work activities listed below: (1) the
effectiveness of the risk assessments performed before maintenance activities were
conducted; (2) the management of risk; (3) that, upon identification of an unforeseen
situation, necessary steps were taken to plan and control the resulting emergent work
activities; and, (4) that maintenance risk assessments and emergent work problems
were adequately identified and resolved. The inspectors verified that the licensee was
complying with the requirements of 10 CFR 50.65(a)(4) and the data output from the
licensees safety monitor associated with the risk profile of Units 1 and 2. The inspectors
reviewed the corrective action program to verify deficiencies in risk assessments were
being identified and properly resolved.
- On-line green risk condition for Units 1 and 2 on August 11associated with planned
maintenance and emergent work on Unit 2 due to component failures in the reactor
protection circuits for the overpower delta temperature (OPDT) instrument and
reactor coolant pump (RCP) under voltage .
- On-line elevated risk (yellow) condition for Units 1 and 2 on August 13 associated
with planned maintenance and emergent work to replace the failed reactor coolant
pump (RCP) under voltage reactor protection relay on Unit 2.
Enclosure
8
- On-line green risk condition for Units 1 and 2 on July 20 associated with the removal
of Circulating Water Piping missile shields.
- On-line green risk condition for Unit 1 on August 6 associated with the operations
surveillance test of the 3A motor driven auxiliary feedwater pump which was
terminated after starting the test.
- On-line green risk condition for Units 1 and 2 on August 24 associated with a
planned entry into a 24-hour shutdown TS LCO for the isolation of the B header of
service water for cleaning and inspection coincident with filter testing of the Auxiliary
Building Emergency Exhaust fans.
b. Findings
No findings were identified.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the three operability evaluations listed below, affecting risk-
significant mitigating systems, to assess as appropriate: (1) the technical adequacy of
the evaluations; (2) whether continued system operability was warranted; (3) whether
other existing degraded conditions were considered; (4) if compensatory measures were
involved, whether the compensatory measures were in place, would work as intended,
and were appropriately controlled; and (5) where continued operability was considered
unjustified, the impact on TS Limiting Conditions for Operation and the risk significance.
The inspectors review included verification that determinations of operability followed
procedural requirements of OP-AA-102, Operability Determination. The inspectors
reviewed the corrective action program to verify deficiencies in operability determinations
were being identified and corrected.
- CR 388265, 1-SW-P-1B in Alert for high engine temperature.
- CR 389798, explosive mixture in pressurizer relief tank.
- CR 386255, Unit 2 cable spreading room fire penetration 1-FP-PEN-2534 has a
gap.
b. Findings:
No findings were identified.
1R18 Plant Modifications
a. Inspection Scope
Reviews of risk significant on-line plant modifications, identified below, were conducted
to verify: (1) that the design and licensing bases, and performance capability of risk-
significant systems, structures, and components (SSCs) were not degraded through
modification; (2) that modifications performed during increased risk-significant
Enclosure
9
configurations do not place the plant in an unsafe condition; and, (3) that the
modification did not affect system operability or functionality as described in the TS and
UFSAR. The inspection was accomplished by review of: engineering evaluations, the
modification design and implementation packages and associated work orders,
drawings, corrective action documents, supporting analyses, the UFSAR and TS,
applicable procedures, and design basis information. Observation of various aspects of
the implementation of the modification and post-modification testing were observed and
or reviewed by the inspectors.
- Component equivalency and modification ET-S-10-0060, Rev. 1; Assembly, Testing,
and Installation for 0.22 microfarad and 150 ohm RC Filter.
- Temporary Modification S-2-10-080 Rev 0, installation/removal of electrical jumpers
needed to facilitate replacement of RCP UV relay 2-RP-RLY-271-XB.
b. Findings:
No findings were identified.
1R19 Post Maintenance Testing
a. Inspection Scope
For the seven risk-significant maintenance activities listed below, the inspectors
reviewed the associated post maintenance testing (PMT) procedures and either
witnessed the testing and/or reviewed completed records to assess whether: (1) the
effect of testing on the plant had been adequately addressed by control room and/or
engineering personnel; (2) testing was adequate for the maintenance performed; (3) test
acceptance criteria were clear and adequately demonstrated operational readiness
consistent with design and licensing basis documents; (4) test instrumentation had
current calibrations, range, and accuracy consistent with the application; (5) test were
performed as written with applicable prerequisites satisfied; (6) jumpers installed or
leads lifted were properly controlled; (7) test equipment was removed following testing;
and (8) equipment was returned to the status required to perform its safety function. The
inspectors reviewed the corrective action program to verify PMT deficiencies were being
identified and corrected. Documents reviewed are listed in the Attachment.
- W.O. 38102836359, investigate/replace failed OP set point indication (2-RC-TM-
2422B).
- W.O. 38076008901, preventive maintenance replacement of expansion joint 2-SW-
REJ-202B.
- Replacement of resistor-capacitor (RC) filters replaced in the Unit 1 Nuclear
Instrumentation Cabinets.
- W.O. 38102835947, replacement of Unit 2 A reactor coolant pump under voltage
relay (2-RP-RLY-271-XB).
- W.O. 38102827974, replacement of start failure relay in start circuit number 1 for
EDG #3
Enclosure
10
- W.O. 38102140934, planned maintenance on the breaker for Unit 1 Service Water
Charging Pump P-10A
- W.O. 38102671689, testing of Unit 1 and Unit 2 Cable Vault Backflow Preventers
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
.1 Unit 2 Forced Outage
a. Inspection Scope
The inspectors, on a sampling basis, verified Technical Specification (TS) requirements
for applicable mode changes were met, plant risk assessments were accurate, and that
cool down and heat up limits were observed, during the forced outage conducted from
July 11 - 16, 2010. The inspectors reviewed licensee calculations for shutdown margin
and the estimated position for criticality and compared results against independent
calculations performed by the inspector. Control room evolutions to startup and place
the Unit on-line were observed by the inspectors. No work was performed in
containment during the forced outage.
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors witnessed and/or reviewed test records for the eight risk-significant
surveillance tests listed below, to determine the SSCs operational readiness and
whether the SSCs selected meet the Technical Specifications (TS), Updated Final
Safety Analysis Report (UFSAR), and licensees procedure requirements and if the test
adequately demonstrated that the SSCs are capable of performing their intended safety
functions (under conditions as close as practical to accident conditions or as required by
TS).
In-Service Testing:
- 1-OPT-CH-002, Rev. 47; Charging Pump Operability and Performance Test for 1-
- 1-NPT-CW-001, Rev. 3, Inservice Inspection and System Pressure Test of 96 inch
Circulating Water Piping.
Enclosure
11
Surveillance Testing:
- 2-PT-8.1, Rev. 32; Reactor Protection System Logic (For Normal Operations)
- 2-OPT-EG-001, Rev. 54; Number 2 Emergency Diesel Generator Monthly Start
Exercise Test.
- 1-NPT-RX-002, Rev. 23, Unit 1 Flux Map
- 0-NSP-CW-001, Rev. 10, High Level Intake Structure Canal Level Probes Cleaning
RCS Leak Rate Determination
- 1-OPT-RC-10.0, Rev. 34, Reactor Coolant Leakage - Computer Calculated
- 2-OPT-RC-10.0, Rev. 33, Reactor Coolant Leakage - Computer Calculated
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP2 Alert and Notification System Testing
a. Inspection Scope
The inspector evaluated the adequacy of licensees methods for testing the alert and
notification system in accordance with NRC Inspection Procedure 71114, Attachment
02, Alert and Notification System Evaluation. The applicable planning standard 10
CFR Part 50.47(b)(5) and its related 10 CFR Part 50, Appendix E, Section IV.D
requirements were used as reference criteria. The criteria contained in NUREG-0654,
Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and
Preparedness in Support of Nuclear Power Plants, Revision 1, was also used as a
reference.
The inspector reviewed various documents which are listed in the Attachment. This
inspection activity satisfied one inspection sample for the alert and notification system on
a biennial basis.
b. Findings
No findings were identified.
1EP3 Emergency Preparedness Organization Staffing and Augmentation System
a. Inspection Scope
The inspector reviewed the licensees Emergency Response Organization (ERO)
augmentation staffing requirements and process for notifying the ERO to ensure the
readiness of key staff for responding to an event and timely facility activation. The
qualification records of key position ERO personnel were reviewed to ensure all ERO
qualifications were current. A sample of problems identified from augmentation drills or
Enclosure
12
system tests performed since the last inspection were reviewed to assess the
effectiveness of corrective actions.
The inspection was conducted in accordance with NRC Inspection Procedure 71114,
Attachment 03, Emergency Response Organization Staffing and Augmentation
System. The applicable planning standard, 10 CFR 50.47(b)(2) and its related 10 CFR
50, Appendix E requirements were used as reference criteria.
The inspector reviewed various documents which are listed in the Attachment. This
inspection activity satisfied one inspection sample for the ERO staffing and
augmentation system on a biennial basis.
b. Findings
The licensee identified a finding of very low significance. The enforcement aspects of
this finding are discussed is Section 4OA7.
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
Since the last NRC inspection of this program area, no change has been implemented to
Revision 54 of the Radiological Emergency Response Plan. The inspector conducted a
sampling review of the Plan changes and implementing procedure changes made
between August 1, 2009, and August 31, 2010 to evaluate for potential decreases in
effectiveness of the Plan. However, this review was not documented in a Safety
Evaluation Report and does not constitute formal NRC approval of the changes.
Therefore, these changes remain subject to future NRC inspection in their entirety.
The inspection was conducted in accordance with NRC Inspection Procedure 71114,
Attachment 04, Emergency Action Level and Emergency Plan Changes. The
applicable planning standard (PS), 10 CFR 50.47(b)(4) and its related 10 CFR 50,
Appendix E requirements were used as reference criteria.
The inspector reviewed various documents which are listed in the Attachment. 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.
1EP5 Correction of Emergency Preparedness Weaknesses
a. Inspection Scope
The inspector reviewed the corrective actions identified through the Emergency
Preparedness program to determine the significance of the issues and to determine if
Enclosure
13
repeat problems were occurring. The facilitys self-assessments and audits were
reviewed to assess the licensees ability to be self-critical, thus avoiding complacency
and degradation of their emergency preparedness program. In addition, the inspector
reviewed licensee self-assessments and audits to assess the completeness and
effectiveness of all emergency preparedness related corrective actions.
The inspection was conducted in accordance with NRC Inspection Procedure 71114,
Attachment 05, Correction of Emergency Preparedness Weaknesses. The applicable
planning standard, 10 CFR 50.47(b)(14) and its related 10 CFR 50, Appendix E
requirements were used as reference criteria.
The inspector reviewed various documents which are listed in the Attachment. This
inspection activity satisfied one inspection sample for the correction of emergency
preparedness weaknesses on a biennial basis.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
a. Inspection Scope
The inspector observed operator simulator training conducted on September 14, 2010,
to assess licensee performance in the risk significant performance standards of
emergency classification, protective action recommendations, and off-site notification.
This drill evaluation is included in the Emergency Response Performance Indicator
statistics.
b. Findings
No findings were identified.
4. OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
.1 Mitigating System Performance Index
a. Inspection Scope
The inspectors reviewed, on a sampling basis, the Mitigating System Performance Index
(MSPI) performance indicators (PI) for Unit 1 and 2 for the third quarter 2008 through the
second quarter 2010. The purpose of the review was to assess the accuracy and
completeness of the submitted PI data and whether the performance indicators were
calculated in accordance with the guidance contained in NEI 99-02, Regulatory
Assessment Performance Indicator Guideline. Inspection included review of the
licensees MSPI basis document, submitted PI data, PI work sheets, licensee event
Enclosure
14
reports (LERs), operator logs, condition reports, plant health reports and NRC inspection
reports. The inspection covered the four Mitigating System Cornerstone performance
indicators below:
- Unit 1 and 2 Heat Removal System (AFW)
b. Findings
No findings were identified.
a. Inspection Scope
The inspector sampled licensee submittals relative to the PIs listed below for the period
July 1, 2009, and June 30, 2010. To verify the accuracy of the PI data reported during
that period, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment
Performance Indicator Guideline, Revision 6, was used to confirm the reporting basis
for each data element.
- Emergency Response Organization Drill/Exercise Performance
- ERO Drill Participation
- Alert and Notification System Reliability
For the specified review period, the inspector examined data reported to the NRC,
procedural guidance for reporting PI information, and records used by the licensee to
identify potential PI occurrences. The inspector verified the accuracy of the PI for ERO
drill and exercise performance through review of a sample of drill and event records.
The inspector 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 inspector
verified the accuracy of the PI for alert and notification system reliability through review
of a sample of the licensees records of periodic system tests. The inspector 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.
b. Findings
No findings were identified.
4OA2 Identification and Resolution of Problems
.1 Daily Reviews of items Entered into the Corrective Action Program:
As required by NRC Inspection Procedure 71152, Identification and Resolution of
Problems, and in order to help identify repetitive equipment failures or specific human
Enclosure
15
performance issues for follow-up, the inspectors performed a daily screening of items
entered into the licensees CAP. This review was accomplished by reviewing daily CR
report summaries and periodically attending daily CR Review Team meetings.
.2 Annual Samples - EDG #1 Failed to Start During Testing (CR 374103)
a. Inspection Scope
Based on risk significance of the Emergency A/C Power Systems and evidence of an
adverse trend associated with fail-to-start and fail-to-load events for all three emergency
diesel generators and the station blackout diesel generator, CR 374103 and its
associated corrective actions were selected for follow-up. The inspectors reviewed the
CR and CAs against the applicable performance attributes contained in NRC inspection
procedure 71152, Problem Identification and Resolution.
b. Findings and Observations
The inspectors identified an extensive history of similar documented events, where the
EDGs failed-to-start during testing, that dated back 12 years. Documented
troubleshooting and cause analyses performed for each event were often sparse and
lacking rigor which made assessing effectiveness of the licensees prior corrective
actions difficult, if not impossible, to determine. The inspector, however, noted following
a fail-to-start event in 2001 (S-2001-3453) on the No. 2 EDG, the licensee identified that
critical relays in the EDGs starting circuits had never been replaced in 30 years of
service. A corrective action was created to institute a replacement PM, on a 12-year
frequency, of all critical relays in each EDG. For reasons that remain unclear, the PM
was not created and entered into the PM tracking system until 2 years later in 2003.
Procurement and engineering issues resulted in further delays and in 2008 a PM
deferral (S-DEF-2008-0071) re-scheduled the relay replacements to coincide with pre-
planned EDG maintenance packages from 2008 through 2014. In March 2010, the No.
1 EDG failed to start during surveillance testing (CR 374103). The root cause team was
not able to establish a definitive cause for the start failure and could not rule out
intermittent failure or faulty actuation of one or more relays in the start circuit; of those
relays, several were original equipment, which had not yet been replaced in accordance
with the established PM that was recommended in 2000. The suspect components in
EDG #1 that could not be ruled out by the root cause team were replaced as well as the
remaining legacy relays present in both start circuits. Though some remain, the licensee
has replaced the majority of legacy relays in the other two EDGs.
4OA3 Event Follow-up
.1 (Closed) LER 05000280/2010-003-00, Loss of Vital Bus Due to Human Error results in
Automatic Reactor Trip.
On June 8, 2010 the Unit 1 120 VAC Vital Bus 1-III was lost when the uninterruptible
power supply (UPS) VB 1-A2 static switch swapped from the inverter to the Regulating
Line Conditioner (RLC) (the alternate AC power source), which was tagged out for on-
going maintenance. The static switch from the inverter swapped because a worker
Enclosure
16
dropped an energized lead during the maintenance. In response to the loss of the vital
bus an automatic reactor trip occurred on Unit 1 from 100% power which was followed
by a subsequent automatic safety injection. Additionally, a small fire, which was
promptly extinguished, broke out in the nuclear instrumentation cabinet within the main
control room when an electrical RC filter failed. The inspectors reviewed the LER for
accuracy, adequacy of corrective actions, and violation of NRC requirements. Details of
the event and associated inspection findings are provided in the NRC Special Inspection
Team (SIT) inspection report, IR 05000280/2010006. This LER is closed.
4OA5 Other Activities
.1 Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope
During the inspection period, the inspectors conducted observations of security force
personnel and activities to ensure that the activities were consistent with the licensee
security procedures and regulatory requirements relating to nuclear plant security.
These observations took place during both normal and off-normal plant working hours.
These quarterly resident inspector observations of security force personnel and activities
did not constitute any additional inspection samples. Rather, they were considered an
integral part of the inspectors normal plant status review and inspection activities.
b. Findings
No findings were identified.
.2 (Closed) URI 05000280, 281/2009007-02, Availability of Portable Ventilation Fans for
Use by the Fire Brigade.
a. Inspection Scope
As described in Unresolved Item (URI) 05000280, 281/2009007-02, the inspectors
identified issues related to the availability of portable ventilation fans for use by the fire
brigade. The inspectors performed an extensive review of the licensees fire protection
program procedures, records of completed drills, and corrective actions relating to the
issues identified by the inspectors.
b. Findings and Observations
NFPA 27-1975, Section 72, Equipment Storage, states that storage space for the
brigade equipment should be provided so that it can be promptly obtained for use and be
properly maintained. The licensee committed to NFPA 27-1975 in their fire protection
plan (FPP).
Enclosure
17
Portable ventilation fans are needed at Surry because no special smoke exhausting
systems are installed at the plant. This condition was recognized in the SER dated
September 19, 1979, as evidenced by Section 4.4.1, Smoke Removal, which states that
no special smoke exhausting systems are provided at the plant. It further states that
when normal ventilation systems cannot be used (for smoke removal), the fire brigade
will use the portable ventilation units with flexible ducting available at the plant for smoke
removal. The ability to remove smoke and provide ventilation in manual fire fighting
situations is important because it can aid the fire brigade in locating the fire source
quickly and it can reduce the likelihood of the formation of hot gas layers which can
damage exposed safe shutdown cabling in overhead raceways. After the licensee was
made aware of the concern, the residents observed the licensee response to additional
fire drills and one actual fire on July 9, 2009. The inspectors concluded, based on these
observations, that the fire brigade is capable of obtaining the required smoke removal
equipment within an acceptable time period.
The inspectors concluded that the failure to provide (smoke removal) brigade equipment
in a location where it can be promptly obtained for use in accordance with NFPA 27-
1975 was a performance deficiency (PD). The PD was not more than of minor
significance because it did not affect the fire brigades ability to extinguish the fire within
the required time. The licensee added this concern to their corrective action program as
CR 343486. In response to the identified concern, the licensee purchased three
additional smoke removal units which will further improve timely access to the smoke
removal equipment throughout the plant and more than doubles their smoke removal
capacity. The licensee has also added the use of portable ventilation equipment to their
fire brigade training. This URI is closed.
.3 Closed: Unresolved Item (URI) 05000280, 281/2010002-01, Emergency Plan Minimum
Staffing
The resident inspectors had previously opened URI 05000280, 281/2010002-01 in NRC
Integrated Inspection Report 05000280, 281/2010002 based on maintenance of the
required minimum on-site staffing requirements in accordance with the licensees
Emergency Plan. The enforcement aspects of this finding are discussed is Section
4OA7. This URI is closed.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On October 14, 2010 the inspection results were presented to Mr. Sloane and other
members of his staff, who acknowledged the findings. The inspectors asked the
licensee whether any of the material examined during the inspection should be
considered proprietary. No proprietary information was identified.
On September 10, 2010, the lead inspector presented the inspection results to Mr. G.
Sloane and other members of his staff. The inspector confirmed that proprietary
information was not provided during the inspection.
Enclosure
18
On September 29, 2010, the lead inspector re-exited with Mr. G. Sloane and other
members of the Surry staff via teleconference. The closure of Unresolved Item (URI)
05000280, 281/2010002-01, Emergency Plan Minimum Staffing was discussed
4OA7 Licensee-Identified Violation
The following finding of very low significance was identified by the licensee and is a
violation of NRC requirements which meets the criteria of Section 2.3.2 of the NRC
Enforcement Policy, NUREG-1600, for characterization as a Green Non-Cited Violation
(NCV).
- 10 CFR 50.54(q) states in part that a licensee authorized to possess and operate
a nuclear power reactor shall follow and maintain in effect emergency plans
which meet the standards in 10 CFR 50.47(b) and the requirements in appendix
E of this part. Contrary to this, between early December 2006 and January 2010,
the licensee identified that the staffing was reduced for mechanical maintenance
and electrical maintenance personnel on shift to below the minimum shift staffing
requirements of the Emergency Plan without a 50.54(q) review. The violation was
determined to be of very low safety significance because, the licensee
demonstrated non-designated coincidental coverage for the shift staffing
positions in question, no degradation of the planning standard existed and the
criteria for a white finding was not met. The licensee corrected the deficiency
when it was discovered and entered it into the corrective action program as
condition report CR364194.
ATTACHMENT: SUPPPLEMENTAL INFORMATION
Enclosure
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
M. Adams, Director, Station Engineering
G. Bischof, Site Vice President
P. Blasioli, Director Nuclear Protection & Emergency Preparedness
E. Collins, Manager Emergency Preparedness
J. Eggart, Manager, Radiation Protection & Chemistry
B. Garber, Supervisor, Licensing
L. Hilbert , Manager Outage and Planning
B. Hoffner, Fleet Emergency Preparedness Manager
R. Johnson, Manager, Operations
C. Olsen, Manager, Site Engineering
K. Sloane, Plant Manager (Nuclear)
M. Smith, Manager Nuclear Oversight
B. Stanley, Director, Station Safety and Licensing
N. Turner, Supervisor Emergency Preparedness
M. Wilda, Supervisor, Auxiliary Systems
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened and Closed
05000280/2010-003-00 LER Loss of Vital Bus Due to Human Error results in
Automatic Reactor Trip (Section 4OA3)
Closed
05000280, 281/2009007-02 URI Availability of Portable Ventilation Fans for Use
by the Fire Brigade (Section 4OA5.2)
05000280, 281/2010002-01 URI Emergency Plan Minimum Staffing (Section
4OA5.3)
Attachment
LIST OF DOCUMENTS REVIEWED
Section 1R04: Equipment Alignment
DWG 11548-FM-068A, Unit 2 Feedwater System
2-OPT-FW-004, Rev. 5; AFW Valve Position Verifications
Section 1R05: Fire Protection
1-FS-FP-200, Rev. 2, Unit 1 High Level Intake Control House Elevation 35FT- 6IN
2-FS-FP-200, Rev. 0, Unit 2 High Level Intake Control House Elevation 35FT- 6IN
0-FS-FP-209, Rev. 1, Intake Vacuum Priming House - Low Level Elevation 37 Feet
0-FS-FP-213, Rev. 0, Intake Structure Transformers - Low Level Elevation 13 Feet
0-FS-FP-211, Rev. 2, Emergency Service Water Pump House - Low Level Elevation 18FT
0-FS-FP-210, Rev. 2, Electrical Equipment Room - Low Level Elevation 12 Feet
Section 1R11: Operability Determination
OP-AA-102, Rev 5; Operability Determination
Section 1R18: Plant Modifications
ET-S-10-0060, Rev. 1; Assembly, Testing, and Installation for 0.22uf and 150 ohm RC filter.
1-PT-1.1, Rev. 36; Nuclear Instrumentation System Trip Channel Test Prior to Startup
IMP-C-NI-19, Rev. 15; Nuclear Instrumentation Maintenance
CAL-048, rev 4, Nuclear Instrument Intermediate Range Drawer
CAL-050, Rev 5; Nuclear Instrument Comparator and Rate Drawer
1-IPT-CC-NI-N42, Rev. 1; Nuclear Instrumentation Power Range N-42 Channel Calibration
0-ECM-1801-01 Rev. 23 OTO1, Westinghouse Type BF-BFD-or-NBFD65NR Relay
Replacement
2-PT-8.1, Rev 32 OTO1; Reactor Protection System Logic (For Normal Operations)
Reactor Protection System DWGs 113E244A sh 3 Rev 15, sh 4 Rev 16, Sh 15 Rev 13, sh 16
Rev 8, sh 17 Rev 5, sh 18 Rev 25 sh 16 Rev 19.
Section 1R19: Post-Maintenance Testing
0-OP-ZZ-008, Rev. 9; Assessment of Maintenance Activities for Potential Flooding of Turbine
Building and Associate Areas
O-MCM-1003-01, Rev. 24; Expansion Joint Removal, Inspection, and Installation
DWG 11548-FM-071A Rev. 56 Circulating and Service Water System Unit 2
NIC work orders: 38102803832, 38102805711, 38102803844, 38102805749, 38102803730,
38102804478, 38102805735, 38102805766, 38102803742, 38102806124, 38102805502,
38102803648, 38102803551, 38102805517, 38102805469, 38102803662, 38102805556,
38102803609.
Section 1R20: Outage
2-OP-RX-002, Rev. 24; Shutdown Margin (Calculated At Zero Power)
2-OP-RX-004, Rev 22; The Calculation of Estimated Critical Conditions
2-GOP-1.4, Rev. 44; Unit Startup, HSD to 2% Reactor Power
2-GOP-1.5, Rev. 55; Unit 1 reactor Startup 2% reactor Power to Max Allowable Power
2-OP-RX-006, Rev 24; Withdrawal of the Control Banks to Critical Conditions
Attachment
3
Section 1EP2: Alert and Notification System Testing
Procedures
Surry Power Station Site-Specific Offsite Radiological Emergency Preparedness Alert and
Notification System Quality Assurance Verification
0-LSP-EW-001, Early Warning System Polling Functional Test, Rev. 7
0-LSP-EW-002, Early Warning System Siren Activation Monitoring, Rev. 7
Records and Data
Early Warning System Polling Function Test results from inspection period
Early Warning System Siren Activation Monitoring Test results from inspection period
Emergency Warning System Surry, Telecommunications Operability (quarterly) Testing from
inspection period
Section 1EP3: Emergency Preparedness Organization Staffing and Augmentation
System
Procedures
DNAP-2605, Emergency Preparedness Performance Indicators, Rev. 10
EPCP-0010, Nuclear Emergency Preparedness Training Program, Rev. 5
EPIP-3.05, Augmentation of Emergency Response Organization, Rev. 6
Records and Data
03/18/2009 Augmentation Capability Assessment - ERO
06/29/2009 Augmentation Capability Assessment - ERO
09/30/2009 Augmentation Capability Assessment - ERO
12/14/2009 Augmentation Capability Assessment - ERO
03/31/2010 Augmentation Capability Assessment - ERO
Section 1EP4: Emergency Action Level and Emergency Plan Changes
Procedures
EP-AA-101, 10 CFR 50.54(q) Change Evaluation, Rev. 2
EPCP-0007, Emergency Preparedness Plan and Procedure Management, Rev. 8
Surry Power Emergency Plan, Rev. 54
Records and Change Packages
EPIP-4.01, Radiological Assessment Director Controlling Procedure, Rev. 24
EPIP-4.03, Dose Assessment Team Controlling Procedure, Rev. 14
EPIP-4.04, Emergency Personnel Radiation Exposure, Rev. 9
EPIP-4.07, Protective Measures, Rev. 13
EPIP-4.21, Evacuation and Remote Assembly Area Monitoring, Rev. 11
Section 1EP5: Correction of Emergency Preparedness Weaknesses
Procedures
PI-AA-200, Corrective Action, Rev. 14
03/18/2009 Self Assessment
Attachment
4
Audits and Self-Assessments
SAR000848, Emergency Response Facilities and Equipment, 08/27/09
10-21-S, Surry May 5th Functional Emergency Exercise SMAY10FE
09-03, Emergency Preparedness, 03/10/09
10-02, Emergency Preparedness, 04/22/10
Condition Reports (CRs)
RCE001000 - Errors in Emergency Classifications, Notifications and Protective Action
Recommendations
CR 383089, Two individuals on Ops Qual listing for NRC Quals were not included on ERO list
CR 319755, Declining ERO performance
CR 112183, Augmentation initiation error
CR 382661, ERO qualification list discrepancy
CR 381918, ERO qualification list not updated
CR 343823, Confusion about TSC accountability card reader light response
CR 343852, RCS sample issues during ERO graded exercise
CR 343921, Operations shift is not meeting expectations for EP exercise critique
CR 344002, Evaluate the process of tracking total dose
CR 343730, Time critical operation during biennial exercise delayed
CR 344050, Confusion of Rad Protection coverage requirements
CA 144818, No more than 5 minute delay of EOP actions
CR 344051, Process for assessing cross-cutting drill/exercise issues is not formalized
CR 350408, Vender made changes to emergency notification protocol without coordination
CR 352266, Surry EP Group Pagers inadvertently activated
CR 352626, ACE 017640 determined an additional PAR opportunity exceeded 15 minutes
CR 353980, Replacement of ANS engineering design document
CR 366945, Audit 10-02 EP program inconsistency for demo and evaluation of station
evacuation
CR 370649, ERO staffing shortfall interim compensatory measures
CR 370898, Compensatory Actions ERF minimum staffing augmentation reduced ERO PI
CR 372760, Dose assessment team performance gaps
CR 378124, Potential applicability of Beaver Valley EP-dose assessment finding to Surry
CR 381021, Expectations for ACA drill ERO performance/response are not being met
CR 386233, ERO Augmentation capabilities for minimum ERO staffing low margin
Section 4OA1: Performance Indicator (PI) Verification
Procedures
EPIP-1.01, Attachment 1, Emergency Action Level Table, Rev 51
EPIP-2.01, Notification of State and Local Governments, Rev. 39
Records and Data
Documentation of Performance Indicator data July 1, 2009, to June 30, 2010, for DEP, ANS,
and ERO
Attachment
5
Section 4OA7: Licensee-Identified Violation
Memorandum of Understanding Maintenance Work Schedules Surry Power Station
Amendment to Surry Power Station Emergency Plan, December 31, 1980
Letter to Mr. H. Denton, Director NRR, contains revised version of Surry Power Station
Emergency Plan, June 30, 1980
Tabulation of hours worked for mechanical and electrical maintenance personnel September 7,
2009 - January 1, 2010
Section 4OA1: Performance Indicator Verification
NEI 99-02, Regulatory Assessment Performance Indicator Guideline.
ER-AA-SPI-1001, Rev. 1, Implementation of the Consolidated Data Entry Reporting for
Mitigating System Performance Index
Attachment
LIST OF ACRONYMS
ADAMS Agencywide Document Access and Management System
ALARA As Low As Reasonably Achievable
ANS Alert and Notification System Testing
CA Corrective Action
CAP Corrective Action Program
CFR Code of Federal Regulations
CR Condition Report
DEP Emergency Response Organization Drill/Exercise Performance
DOT Department of Transportation
EAL Emergency Action Level
EDG Emergency Diesel Generator
ERO Emergency Response Organization
HP Health Physics
HPT Health Physics Technician
HPAP Health Physics Administrative Procedure
IMC Inspection Manual Chapter
ISFSI Independent Spent Fuel Storage Installation
LHSI Low Head Safety Injection
NCV Non-cited Violation
NEI Nuclear Energy Institute
NRC Nuclear Regulatory Commission
PARS Publicly Available Records
PI Performance Indicator
PS Planning Standard
QS Quench Spray
RAB Reactor Auxiliary Building
RCE Root Cause Evaluation
RCP Reactor Coolant Pump
RFO Refueling Outage
RP Radiation Protection
RTP Rated Thermal Power
RWP Radiation Work Permit
SDP Significance Determination Process
SR Surveillance Requirements
TDAFWP Turbine Driven Auxiliary Feedwater Pump
TS Technical Specifications
UFSAR Updated Final Safety Analysis Report
URI Unresolved Item
VEPCO Virginia Electric and Power Company
VHRA Very High Radiation Area
VPAP Virginia Power Administrative Procedure
WO Work Order
Attachment
7
ALARA As Low As Reasonably Achievable
CAP Corrective Action Program
CFR Code of Federal Regulations
CR Condition Report
HP Health Physics
HPT Health Physics Technician
Attachment