IR 05000280/2023003: Difference between revisions

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=Text=
=Text=
{{#Wiki_filter:October 25, 2023
{{#Wiki_filter:==SUBJECT:==
 
==SUBJECT:==
SURRY POWER STATION - INTEGRATED INSPECTION REPORT 05000280/2023003 AND 05000281/2023003
SURRY POWER STATION - INTEGRATED INSPECTION REPORT 05000280/2023003 AND 05000281/2023003


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This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.


Sincerely, Signed by Fannon, Matthew on 10/25/23 Matthew S. Fannon, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 05000280 and 05000281 License Nos. DPR-32 and DPR-37
October 25, 2023
 
Sincerely, Matthew S. Fannon, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 05000280 and 05000281 License Nos. DPR-32 and DPR-37


===Enclosure:===
===Enclosure:===
As stated
As stated  


==Inspection Report==
==Inspection Report==
Docket Numbers: 05000280 and 05000281 License Numbers: DPR-32 and DPR-37 Report Numbers: 05000280/2023003 and 05000281/2023003 Enterprise Identifier: I-2023-003-0031 Licensee: Virginia Electric and Power Company Facility: Surry Power Station Location: Surry, VA Inspection Dates: July 01, 2023 to September 30, 2023 Inspectors: P. Gresh, Operations Engineer D. Jung, Resident Inspector S. Kennedy, Senior Resident Inspector J. Tornow, Physical Security Inspector B. Towne, Senior Resident Inspector J. Walker, Senior Emergency Preparedness Inspector A. Wilson, Senior Project Engineer Approved By: Matthew S. Fannon, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
Docket Numbers:
05000280 and 05000281
License Numbers:
DPR-32 and DPR-37
Report Numbers:
05000280/2023003 and 05000281/2023003
Enterprise Identifier:
I-2023-003-0031
Licensee:
Virginia Electric and Power Company
Facility:
Surry Power Station
Location:
Surry, VA
Inspection Dates:
July 01, 2023 to September 30, 2023
Inspectors:
P. Gresh, Operations Engineer
D. Jung, Resident Inspector
S. Kennedy, Senior Resident Inspector
J. Tornow, Physical Security Inspector
B. Towne, Senior Resident Inspector
J. Walker, Senior Emergency Preparedness Inspector
A. Wilson, Senior Project Engineer
Approved By:
Matthew S. Fannon, Chief
Reactor Projects Branch 4
Division of Reactor Projects


=SUMMARY=
=SUMMARY=
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===List of Findings and Violations===
===List of Findings and Violations===
 
Transient Combustibles Stored in Restricted Areas Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000280,05000281/2023003-01 Open/Closed
Transient Combustibles Stored in Restricted Areas Cornerstone           Significance                               Cross-Cutting     Report Aspect            Section Mitigating             Green                                     [P.3] -          71152A Systems                NCV 05000280,05000281/2023003-01           Resolution Open/Closed The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of License Condition 3.I, Fire Protection, associated with the licensee's failure to implement and maintain in effect, the provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR), which resulted in storage of transient combustibles within restricted or combustion free zones in various areas of Unit 1 and Unit 2.
[P.3] -
Resolution 71152A The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of License Condition 3.I, Fire Protection, associated with the licensee's failure to implement and maintain in effect, the provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR), which resulted in storage of transient combustibles within restricted or combustion free zones in various areas of Unit 1 and Unit 2.


===Additional Tracking Items===
===Additional Tracking Items===
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==REACTOR SAFETY==
==REACTOR SAFETY==
==71111.04 - Equipment Alignment==
==71111.04 - Equipment Alignment==
===Partial Walkdown Sample (IP Section 03.01) (3 Samples)===
===Partial Walkdown Sample (IP Section 03.01) (3 Samples)===
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
: (1) Diverse and flexible coping strategies beyond design basis equipment in the equipment dome on August 7, 2023 (2)     #1 emergency diesel generator following routine surveillance on September 12, 2023
: (1) Diverse and flexible coping strategies beyond design basis equipment in the equipment dome on August 7, 2023 (2)
#1 emergency diesel generator following routine surveillance on September 12, 2023
: (3) Control room ventilation following failure of 1-VS-MOD-103C, control room supply isolation motor operated damper, on September 25, 2023
: (3) Control room ventilation following failure of 1-VS-MOD-103C, control room supply isolation motor operated damper, on September 25, 2023


==71111.05 - Fire Protection==
==71111.05 - Fire Protection==
===Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)===
===Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)===
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
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===Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)===
===Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)===
: (1) Fire brigade drill performance observation for unannounced simulated fire in Unit 2           turbine building basement from the B instrument air compressor, on August 15, 2023
: (1) Fire brigade drill performance observation for unannounced simulated fire in Unit 2 turbine building basement from the B instrument air compressor, on August 15, 2023


==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance==
==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance==
===Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)===
===Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)===
: (1) The inspectors observed and evaluated licensed operator requalification training involving a scenario which included a loss of all instrument and station air requiring a manual reactor trip and emergency boration on September 13, 2023.
: (1) The inspectors observed and evaluated licensed operator requalification training involving a scenario which included a loss of all instrument and station air requiring a manual reactor trip and emergency boration on September 13, 2023.


==71111.12 - Maintenance Effectiveness==
==71111.12 - Maintenance Effectiveness==
===Maintenance Effectiveness (IP Section 03.01) (1 Sample)===
===Maintenance Effectiveness (IP Section 03.01) (1 Sample)===
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
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==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
===Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)===
===Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)===
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
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==71111.15 - Operability Determinations and Functionality Assessments==
==71111.15 - Operability Determinations and Functionality Assessments==
===Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)===
===Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)===
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
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==71111.18 - Plant Modifications==
==71111.18 - Plant Modifications==
 
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
The inspectors evaluated the following temporary or permanent modifications:
: (1) Design Equivalent Change Package SU-23-00112, Temporary Chiller for 1-VS-AC-3 Mechanical Equipment Room-2 AC Unit, on August 16, 2023
: (1) Design Equivalent Change Package SU-23-00112, Temporary Chiller for 1-VS-AC-3 Mechanical Equipment Room-2 AC Unit, on August 16, 2023
: (2) Design Equivalent Change Package SU-23-00117, Isolation of Flux Thimble 2-RC-TW-R8, on September 26, 2023
: (2) Design Equivalent Change Package SU-23-00117, Isolation of Flux Thimble 2-RC-TW-R8, on September 26, 2023
==71111.24 - Testing and Maintenance of Equipment Important to Risk==
==71111.24 - Testing and Maintenance of Equipment Important to Risk==
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:


The inspectors evaluated the following testing and maintenance activities to verify system
===Post-Maintenance Testing (PMT) (IP Section 03.01) (5 Samples)===
 
(1)0-MOP-SW-001, Removal from Service and Return to Service of Emergency Service Water Pumps, following repair of leak on 'A' emergency service water pump fuel oil line on August 2, 2023 (2)1-OPT-SI-005, Low Head Safety Injection Pump Test, following drain and refill of the seal head tank on August 9, 2023
===operability and/or functionality: Post-Maintenance Testing (PMT) (IP Section 03.01)===
: (3) PMT-BKR-OP-01, Breaker Operability Test, following 10-year planned refurbishment of 01-IP-BKR-15H10-CKTBRK, component cooling pump 1A circuit breaker, August 24, 2023 (4)2-IPT-CC-CW-L-202, Intake Canal Level Probe Time Response and Calibration, following cleaning of channel 3 canal level probe on September 1, 2023 (5)2-OPT-RC-11.1, 10-Year Inservice Inspection System Pressure Test of Class 1 Components Associated with the Reactor Coolant System, following installation of plug for flux thimble 2-RC-TW-R8 on September 22, 2023
{{IP sample|IP=IP 71111.24|count=5}}
: (1) 0-MOP-SW-001, Removal from Service and Return to Service of Emergency Service Water Pumps, following repair of leak on 'A' emergency service water pump fuel oil line on August 2, 2023
: (2) 1-OPT-SI-005, Low Head Safety Injection Pump Test, following drain and refill of the seal head tank on August 9, 2023
: (3) PMT-BKR-OP-01, Breaker Operability Test, following 10-year planned refurbishment of 01-IP-BKR-15H10-CKTBRK, component cooling pump 1A circuit breaker, August 24, 2023
: (4) 2-IPT-CC-CW-L-202, Intake Canal Level Probe Time Response and Calibration, following cleaning of channel 3 canal level probe on September 1, 2023
: (5) 2-OPT-RC-11.1, 10-Year Inservice Inspection System Pressure Test of Class 1 Components Associated with the Reactor Coolant System, following installation of plug for flux thimble 2-RC-TW-R8 on September 22, 2023


===Surveillance Testing (IP Section 03.01) (5 Samples)===
===Surveillance Testing (IP Section 03.01) (5 Samples)===
: (1) 2-NPT-FW-001, Inservice Inspection System Pressure Test of the Suction Flow Path from the Fire Protection System to the Auxiliary Feedwater Pumps, on August 2, 2023
(1)2-NPT-FW-001, Inservice Inspection System Pressure Test of the Suction Flow Path from the Fire Protection System to the Auxiliary Feedwater Pumps, on August 2, 2023 (2)2-OSP-ZZ-001, Auxiliary Shutdown Panel Functional Surveillance, on August 3, 2023 (3)2-OPT-ZZ-002, Engineered Safety Features Actuation with Undervoltage and Degraded Voltage - 2J Bus, on August 4, 2023 (4)2-OPT-CS-006, Containment Spray System Motor Operated Valve Stroke Test, on August 28, 2023 (5)0-OSP-AAC-003, 18 Month Frequency: Automatic Start Test of AAC Diesel Generator, on August 29, 2023
: (2) 2-OSP-ZZ-001, Auxiliary Shutdown Panel Functional Surveillance, on August 3, 2023
: (3) 2-OPT-ZZ-002, Engineered Safety Features Actuation with Undervoltage and Degraded Voltage - 2J Bus, on August 4, 2023
: (4) 2-OPT-CS-006, Containment Spray System Motor Operated Valve Stroke Test, on August 28, 2023
: (5) 0-OSP-AAC-003, 18 Month Frequency: Automatic Start Test of AAC Diesel Generator, on August 29, 2023


==71114.01 - Exercise Evaluation==
==71114.01 - Exercise Evaluation==
===Inspection Review (IP Section 02.01-02.11) (1 Sample)===
===Inspection Review (IP Section 02.01-02.11) (1 Sample)===
: (1) The inspectors evaluated the biennial emergency plan exercise during the week of July 17, 2023. The simulated scenario began with a loose parts alarm in the lower reactor vessel, followed by a high radiation alarm from the reactor coolant system letdown radiation monitor. This met the conditions for declaring a Notice of Unusual Event. Subsequently, a steam generator tube rupture occurred resulting in the loss of reactor coolant system boundary, meeting the conditions for declaring an Alert. As the scenario progressed, a main steam safety valve on the effected steam generator failed open, meeting the conditions for a Site Area Emergency. When off-site field team readings exceeded threshold criteria, conditions for a General Emergency were met, and the Offsite Response Organizations were able to demonstrate their ability to implement emergency actions.
: (1) The inspectors evaluated the biennial emergency plan exercise during the week of July 17, 2023. The simulated scenario began with a loose parts alarm in the lower reactor vessel, followed by a high radiation alarm from the reactor coolant system letdown radiation monitor. This met the conditions for declaring a Notice of Unusual Event. Subsequently, a steam generator tube rupture occurred resulting in the loss of reactor coolant system boundary, meeting the conditions for declaring an Alert. As the scenario progressed, a main steam safety valve on the effected steam generator failed open, meeting the conditions for a Site Area Emergency. When off-site field team readings exceeded threshold criteria, conditions for a General Emergency were met, and the Offsite Response Organizations were able to demonstrate their ability to implement emergency actions.


==71114.04 - Emergency Action Level and Emergency Plan Changes==
==71114.04 - Emergency Action Level and Emergency Plan Changes==
===Inspection Review (IP Section 02.01-02.03) (1 Sample)===
===Inspection Review (IP Section 02.01-02.03) (1 Sample)===
: (1) The inspectors evaluated submitted Emergency Action Level, Emergency Plan, and Emergency Plan Implementing Procedure changes during the week of July 17, 2023. This evaluation does not constitute NRC approval.
: (1) The inspectors evaluated submitted Emergency Action Level, Emergency Plan, and Emergency Plan Implementing Procedure changes during the week of July 17, 2023. This evaluation does not constitute NRC approval.


==71114.06 - Drill Evaluation==
==71114.06 - Drill Evaluation==
===Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)===
===Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)===
The inspectors evaluated:
The inspectors evaluated:
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==71114.08 - Exercise Evaluation - Scenario Review==
==71114.08 - Exercise Evaluation - Scenario Review==
===Inspection Review (IP Section 02.01 - 02.04) (1 Sample)===
===Inspection Review (IP Section 02.01 - 02.04) (1 Sample)===
: (1) The inspectors reviewed and evaluated in-office, the proposed scenario for the             biennial emergency plan exercise prior to the day of the exercise.
: (1) The inspectors reviewed and evaluated in-office, the proposed scenario for the biennial emergency plan exercise prior to the day of the exercise.


==OTHER ACTIVITIES - BASELINE==
==OTHER ACTIVITIES - BASELINE==
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
{{IP sample|IP=IP 71151|count=2}}
{{IP sample|IP=IP 71151|count=2}}
: (1) Unit 1 (July 2022 through June 2023)
: (1) Unit 1 (July 2022 through June 2023)
: (2) Unit 2 (July 2022 through June 2023)
: (2) Unit 2 (July 2022 through June 2023)  


===MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)===
===MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)===
: (1) Unit 1 (January 2022 through December 2022)
: (1) Unit 1 (January 2022 through December 2022)
: (2) Unit 2 (January 2022 through December 2022)
: (2) Unit 2 (January 2022 through December 2022)  


===MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)===
===MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)===
: (1) Unit 1 (January 2022 through December 2022)
: (1) Unit 1 (January 2022 through December 2022)
: (2) Unit 2 (January 2022 through December 2022)
: (2) Unit 2 (January 2022 through December 2022)  


===MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)===
===MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)===
: (1) Unit 1 (January 2022 through December 2022)
: (1) Unit 1 (January 2022 through December 2022)
: (2) Unit 2 (January 2022 through December 2022)
: (2) Unit 2 (January 2022 through December 2022)  


===MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)===
===MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)===
: (1) Unit 1 (January 2022 through December 2022)
: (1) Unit 1 (January 2022 through December 2022)
: (2) Unit 2 (January 2022 through December 2022)
: (2) Unit 2 (January 2022 through December 2022)  


===MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)===
===MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)===
: (1) Unit 1 (January 2022 through December 2022)
: (1) Unit 1 (January 2022 through December 2022)
: (2) Unit 2 (January 2022 through December 2022)
: (2) Unit 2 (January 2022 through December 2022)  


===EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)===
===EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)===
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: (1) July 1, 2022, through March 31, 2023
: (1) July 1, 2022, through March 31, 2023


===71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03) ===
===71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)===
{{IP sample|IP=IP 71152|count=2}}
{{IP sample|IP=IP 71152|count=2}}
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
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==INSPECTION RESULTS==
==INSPECTION RESULTS==
Transient Combustibles Stored in Restricted Areas Cornerstone           Significance                             Cross-Cutting     Report Aspect            Section Mitigating             Green                                     [P.3] -            71152A Systems                NCV 05000280,05000281/2023003-01 Resolution Open/Closed The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of License Condition 3.I, Fire Protection, associated with the licensee's failure to implement and maintain in effect, the provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR), which resulted in storage of transient combustibles within restricted or combustion free zones in various areas of Unit 1 and Unit 2.
Transient Combustibles Stored in Restricted Areas Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000280,05000281/2023003-01 Open/Closed
[P.3] -
Resolution 71152A The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of License Condition 3.I, Fire Protection, associated with the licensee's failure to implement and maintain in effect, the provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR), which resulted in storage of transient combustibles within restricted or combustion free zones in various areas of Unit 1 and Unit 2.


=====Description:=====
=====Description:=====
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=DOCUMENTS REVIEWED=
=DOCUMENTS REVIEWED=


Inspection Type             Designation   Description or Title                                     Revision or
Inspection
Procedure                                                                                          Date
Procedure
71114.01  Corrective Action CR1179951     ANS Evaluation Report                                   10/22/2022
Type
Documents        CR1182798     NRC ENS line is non-functional                           10/15/2021
Designation
CR1209676     Offsite Notifications                                   10/06/2022
Description or Title
CR1223366     RP below ERO minimum shift manning requirements         4/5/23
Revision or
CR1224246     State and Local Comm selected 'Emergency' vs. 'Drill' on 4/12/2023
Date
CR1179951
ANS Evaluation Report
10/22/2022
CR1182798
NRC ENS line is non-functional
10/15/2021
CR1209676
Offsite Notifications
10/06/2022
CR1223366
RP below ERO minimum shift manning requirements
4/5/23
CR1224246
State and Local Comm selected 'Emergency' vs. 'Drill' on
ENF
ENF
CR1228173     TSC UPS failed to transfer to its normal source         5/12/23
4/12/2023
CR1231023     Unexpected response in MIDAS during drill               6/15/23
CR1228173
Procedures                      Surry Emergency Plan                                     Rev. 72
TSC UPS failed to transfer to its normal source
0-AP-37.00   Seismic Event                                           21
5/12/23
0-LSP-J-W-001 Early Warning System Polling Functional Test             1/11/2022
Corrective Action
EPIP 3.03     ACTIVATION OF OPERATIONAL SUPPORT CENTER                 Rev. 27
Documents
EPIP-1.01     Emergency Manager Controller Procedure                   63
CR1231023
EPIP-1.01     Emergency Manager Controlling Procedure                 Rev. 63
Unexpected response in MIDAS during drill
EPIP-1.02     Response to Notification of Unusual Event               17
6/15/23
EPIP-1.03     Response to Alert                                       24
Surry Emergency Plan
EPIP-1.04     Response to Site Area Emergency                         26
Rev. 72
EPIP-1.05     Response to General Emergency                           28
0-AP-37.00
EPIP-1.06     Protective Action Recommendations                       15
Seismic Event
EPIP-1.06     Protective Action Recommendations                       15
0-LSP-J-W-001
EPIP-2.01     Notifications and Communications                         48
Early Warning System Polling Functional Test
EPIP-2.02     Notification of NRC                                     25
1/11/2022
EPIP-3.02     Activation of the TSC                                   41
EPIP 3.03
EPIP-3.06     Corporate Emergency Response Center Activation           Rev. 2
ACTIVATION OF OPERATIONAL SUPPORT CENTER
EPIP-3.10     CERC Technical Support Controlling Procedure             3
Rev. 27
EPIP-4.01     Radiological Assessment Director Controlling Procedure   33
EPIP-1.01
EPIP-4.02     Radiation Protection Supervisor Controlling Procedure   27
Emergency Manager Controller Procedure
EPIP-4.03     Dose Assessment Team Controlling Procedure               24
EPIP-1.01
EPIP-4.04     Emergency Personnel Radiation Exposure                   11
Emergency Manager Controlling Procedure
EPIP-4.07     Protective Measures                                     21
Rev. 63
EPIP-4.09     Source Term Assessment                                   22
EPIP-1.02
Inspection Type         Designation Description or Title                                   Revision or
Response to Notification of Unusual Event
Procedure                                                                                    Date
EPIP-1.03
EPIP-4.15   Onsite Monitoring                                       10
Response to Alert
EPIP-4.34   Field Team Radio Operator Rev 10                       11
EPIP-1.04
EPIP-5.01   Transportation of Contaminated Injured Personnel       18
Response to Site Area Emergency
EPIP-5.03   Personnel Accountability                               Rev. 26
EPIP-1.05
EPIP-5.09   Attacks Against Station, Security Threat or Security   20
Response to General Emergency
EPIP-1.06
Protective Action Recommendations
EPIP-1.06
Protective Action Recommendations
EPIP-2.01
Notifications and Communications
EPIP-2.02
Notification of NRC
EPIP-3.02
Activation of the TSC
EPIP-3.06
Corporate Emergency Response Center Activation
Rev. 2
EPIP-3.10
CERC Technical Support Controlling Procedure
EPIP-4.01
Radiological Assessment Director Controlling Procedure
EPIP-4.02
Radiation Protection Supervisor Controlling Procedure
EPIP-4.03
Dose Assessment Team Controlling Procedure
EPIP-4.04
Emergency Personnel Radiation Exposure
EPIP-4.07
Protective Measures
71114.01
Procedures
EPIP-4.09
Source Term Assessment
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
EPIP-4.15
Onsite Monitoring
EPIP-4.34
Field Team Radio Operator Rev 10
EPIP-5.01
Transportation of Contaminated Injured Personnel
EPIP-5.03
Personnel Accountability
Rev. 26
EPIP-5.09
Attacks Against Station, Security Threat or Security
Condition
Condition
71114.04  Miscellaneous SU-22-01-0 50.54(q) Change Package for SPS EAL Matrix and EAL     7
SU-22-01-0
50.54(q) Change Package for SPS EAL Matrix and EAL
Technical Basis Document
Technical Basis Document
SU-22-02-0 50.54(q) Change Package for Surry LBCDR 463             1/18/22
SU-22-02-0
SU-22-03-0 50.54(q) Change Package for EPIP 3.02 Activation of the 41
50.54(q) Change Package for Surry LBCDR 463
1/18/22
SU-22-03-0
50.54(q) Change Package for EPIP 3.02 Activation of the
TSC
TSC
SU-22-05-0 50.54(q) Change Package for SPS EAL Matrix and EAL     7
SU-22-05-0
50.54(q) Change Package for SPS EAL Matrix and EAL
Technical Basis Document
Technical Basis Document
SU-22-06-0 50.54(q) Change Package for EPIP-4.34 Field Team Radio 10
SU-22-06-0
50.54(q) Change Package for EPIP-4.34 Field Team Radio
Operator Rev 10
Operator Rev 10
SU-22-07-0 50.54(q) Change Package for EPIP-3.10 CERC Technical   3
SU-22-07-0
50.54(q) Change Package for EPIP-3.10 CERC Technical
Support Controlling Procedure
Support Controlling Procedure
SU-22-08   50.54(q) Change Package for EPIP-1.06 Protective Action 15
SU-22-08
50.54(q) Change Package for EPIP-1.06 Protective Action
Recommendations
Recommendations
SU-22-09-0 50.54(q) Change Package for EPIP-3.03 Activation of the 27
SU-22-09-0
50.54(q) Change Package for EPIP-3.03 Activation of the
OSC
OSC
SU-22-11-0 50.54(q) Change Package for EPIP-4.07 Protective       21
SU-22-11-0
50.54(q) Change Package for EPIP-4.07 Protective
Measures
Measures
SU-23-01-0 50.54(q) Change Package for EPIP-5.01 Transportation of 18
SU-23-01-0
50.54(q) Change Package for EPIP-5.01 Transportation of
Contaminated Injured Personnel
Contaminated Injured Personnel
SU-23-02-0 50.54(q) Change Package for EPIP-1.01 Emergency         63
SU-23-02-0
50.54(q) Change Package for EPIP-1.01 Emergency
Manager Controller Procedure
Manager Controller Procedure
SU-23-03-0 Update to EPIP-4.03, Dose Assessment Team Controlling   02/08/2023
SU-23-03-0
Update to EPIP-4.03, Dose Assessment Team Controlling
Procedure - EPIP-4.03, Rev. 24
Procedure - EPIP-4.03, Rev. 24
SU-23-04-0 EPIP-5.09 Attacks Against Station, Security Threat or   20
2/08/2023
SU-23-04-0
EPIP-5.09 Attacks Against Station, Security Threat or
Security Condition
Security Condition
SU-23-05-0 50.54(q) Change Package for 0-AP-37.00 Seismic Event   21
SU-23-05-0
SU-23-06-0 50.54(q) Change Package for EPIP-4.01 Radiological     33
50.54(q) Change Package for 0-AP-37.00 Seismic Event
71114.04
Miscellaneous
SU-23-06-0
50.54(q) Change Package for EPIP-4.01 Radiological
Assessment Director Controlling Procedure
Assessment Director Controlling Procedure
Inspection Type             Designation Description or Title                                     Revision or
 
Procedure                                                                                        Date
Inspection
SU-23-07-0 50.54(q) Change Package for EPIP-4.02 Radiation         27
Procedure
Type
Designation
Description or Title
Revision or
Date
SU-23-07-0
50.54(q) Change Package for EPIP-4.02 Radiation
Protection Supervisor Controlling Procedure
Protection Supervisor Controlling Procedure
SU-23-08-02 50.54(q) Change Package for EPIP-4.04 Emergency         11
SU-23-08-02
50.54(q) Change Package for EPIP-4.04 Emergency
Personnel Radiation Exposure
Personnel Radiation Exposure
SU-23-09-01 50.54(q) Change Package for EPIP-4.09 Source Term       22
SU-23-09-01
50.54(q) Change Package for EPIP-4.09 Source Term
Assessment
Assessment
SU-23-10-0 50.54(q) Change Package for EPIP-4.15 Onsite Monitoring 10
SU-23-10-0
SU-23-11-1 50.54(q) Change Package for EPIP-4.16 Offsite Monitoring 19
50.54(q) Change Package for EPIP-4.15 Onsite Monitoring
SU-23-12-0 50.54(q) Change Package for EPIP-4.34 Field Team Radio   11
SU-23-11-1
50.54(q) Change Package for EPIP-4.16 Offsite Monitoring
SU-23-12-0
50.54(q) Change Package for EPIP-4.34 Field Team Radio
Operator Rev 10
Operator Rev 10
SU-23-13-0 50.54(q) Change Package for 0-LSP-CO-005 Rev 2           6/26/23
SU-23-13-0
Procedures        EAL         Surry Power Station Emergency Action Level Matrix       Rev. 6
50.54(q) Change Package for 0-LSP-CO-005 Rev 2
EAL         Surry Power Station Emergency Action Level Matrix       Rev. 7
6/26/23
71151      Corrective Action CR1225406  Unsuccessful DEP opportunity from 4/4/2023 drill (CERC)  4/21/2023
EAL
Surry Power Station Emergency Action Level Matrix
Rev. 6
Procedures
EAL
Surry Power Station Emergency Action Level Matrix
Rev. 7
Corrective Action
Documents
Documents
Miscellaneous                 2nd quarter 2022 through 1st quarter 2023 PI data.
CR1225406
Procedures       EP-AA-103   Emergency Preparedness Performance Indicators           Rev. 11
Unsuccessful DEP opportunity from 4/4/2023 drill (CERC)
13
4/21/2023
Miscellaneous
2nd quarter 2022 through 1st quarter 2023 PI data.
71151
Procedures
EP-AA-103
Emergency Preparedness Performance Indicators
Rev. 11
}}
}}

Latest revision as of 17:04, 2 January 2025

Integrated Inspection Report 05000280/2023003 and 05000281/2023003
ML23296A031
Person / Time
Site: Surry  Dominion icon.png
Issue date: 10/25/2023
From: Matthew Fannon
Division Reactor Projects II
To: Carr E
Virginia Electric & Power Co (VEPCO)
References
IR 2023003
Download: ML23296A031 (1)


Text

SUBJECT:

SURRY POWER STATION - INTEGRATED INSPECTION REPORT 05000280/2023003 AND 05000281/2023003

Dear Eric S. Carr:

On September 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Surry Power Station. On October 16, 2023, the NRC inspectors discussed the results of this inspection with David Wilson, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Surry Power Station.

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

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

October 25, 2023

Sincerely, Matthew S. Fannon, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 05000280 and 05000281 License Nos. DPR-32 and DPR-37

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000280 and 05000281

License Numbers:

DPR-32 and DPR-37

Report Numbers:

05000280/2023003 and 05000281/2023003

Enterprise Identifier:

I-2023-003-0031

Licensee:

Virginia Electric and Power Company

Facility:

Surry Power Station

Location:

Surry, VA

Inspection Dates:

July 01, 2023 to September 30, 2023

Inspectors:

P. Gresh, Operations Engineer

D. Jung, Resident Inspector

S. Kennedy, Senior Resident Inspector

J. Tornow, Physical Security Inspector

B. Towne, Senior Resident Inspector

J. Walker, Senior Emergency Preparedness Inspector

A. Wilson, Senior Project Engineer

Approved By:

Matthew S. Fannon, Chief

Reactor Projects Branch 4

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Surry Power Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Transient Combustibles Stored in Restricted Areas Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000280,05000281/2023003-01 Open/Closed

[P.3] -

Resolution 71152A The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of License Condition 3.I, Fire Protection, associated with the licensee's failure to implement and maintain in effect, the provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR), which resulted in storage of transient combustibles within restricted or combustion free zones in various areas of Unit 1 and Unit 2.

Additional Tracking Items

None.

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 activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.04 - Equipment Alignment

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

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

(1) Diverse and flexible coping strategies beyond design basis equipment in the equipment dome on August 7, 2023 (2)
  1. 1 emergency diesel generator following routine surveillance on September 12, 2023
(3) Control room ventilation following failure of 1-VS-MOD-103C, control room supply isolation motor operated damper, on September 25, 2023

71111.05 - Fire Protection

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

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Security central alarm station, elevation 27 feet, on July 20, 2023
(2) Unit 1 safeguards building valve room and low head safety injection pump cubes, elevations 27 feet, 19 feet, and 12 feet, on August 10, 2023
(3) Fire pump house, elevation 27 feet, on August 13, 2023
(4) Unit 1 cable vault penetration area, elevation 15 feet, on August 24, 2023

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) Fire brigade drill performance observation for unannounced simulated fire in Unit 2 turbine building basement from the B instrument air compressor, on August 15, 2023

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator requalification training involving a scenario which included a loss of all instrument and station air requiring a manual reactor trip and emergency boration on September 13, 2023.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Unit 1 and Unit 2 switchgear rooms backflow preventer valves

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Unit 1 and Unit 2 emergent risk assessment due to 'A' emergency service water pump emergent fuel oil line repair on July 31, 2023
(2) High risk plan assessment for replacement of electronic module in Unit 1 turbine control system on August 3, 2023
(3) Unit 1 and Unit 2 elevated risk due to #2 emergency diesel generator and canal level probe testing on September 18, 2023
(4) Unit 1 and Unit 2 elevated risk due to the alternate AC diesel maintenance on September 26, 2023

71111.15 - Operability Determinations and Functionality Assessments

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

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

(1) Condition Report (CR) 1232411, Unit 1 boric acid transfer pump failure of 1-CH-FI-1180, boric acid filter outlet flow indicator, on July 3, 2023
(2) CR1234395, 1-VS-AC-2, Unit 1 control room air handling unit, high current readings on July 31, 2023
(3) CR1234933, Unit 2 C charging pump discharge sample valve, 2-SS-HCV-203C, failed to close during performance of 2-NPT-CH-003, In-service Inspection of 2-CH-P-1C, on August 7, 2023
(4) CR1235475, Seismic support spring can to trunnion misalignment on A and B auxiliary feedwater injection headers near containment penetrations, on August 14, 2023
(5) CR1236002, Rising Unit 2 pressurizer power operated relief valve tailpipe temperatures after draining pressurizer relief tank on August 22, 2023

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Design Equivalent Change Package SU-23-00112, Temporary Chiller for 1-VS-AC-3 Mechanical Equipment Room-2 AC Unit, on August 16, 2023
(2) Design Equivalent Change Package SU-23-00117, Isolation of Flux Thimble 2-RC-TW-R8, on September 26, 2023

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01) (5 Samples)

(1)0-MOP-SW-001, Removal from Service and Return to Service of Emergency Service Water Pumps, following repair of leak on 'A' emergency service water pump fuel oil line on August 2, 2023 (2)1-OPT-SI-005, Low Head Safety Injection Pump Test, following drain and refill of the seal head tank on August 9, 2023

(3) PMT-BKR-OP-01, Breaker Operability Test, following 10-year planned refurbishment of 01-IP-BKR-15H10-CKTBRK, component cooling pump 1A circuit breaker, August 24, 2023 (4)2-IPT-CC-CW-L-202, Intake Canal Level Probe Time Response and Calibration, following cleaning of channel 3 canal level probe on September 1, 2023 (5)2-OPT-RC-11.1, 10-Year Inservice Inspection System Pressure Test of Class 1 Components Associated with the Reactor Coolant System, following installation of plug for flux thimble 2-RC-TW-R8 on September 22, 2023

Surveillance Testing (IP Section 03.01) (5 Samples)

(1)2-NPT-FW-001, Inservice Inspection System Pressure Test of the Suction Flow Path from the Fire Protection System to the Auxiliary Feedwater Pumps, on August 2, 2023 (2)2-OSP-ZZ-001, Auxiliary Shutdown Panel Functional Surveillance, on August 3, 2023 (3)2-OPT-ZZ-002, Engineered Safety Features Actuation with Undervoltage and Degraded Voltage - 2J Bus, on August 4, 2023 (4)2-OPT-CS-006, Containment Spray System Motor Operated Valve Stroke Test, on August 28, 2023 (5)0-OSP-AAC-003, 18 Month Frequency: Automatic Start Test of AAC Diesel Generator, on August 29, 2023

71114.01 - Exercise Evaluation

Inspection Review (IP Section 02.01-02.11) (1 Sample)

(1) The inspectors evaluated the biennial emergency plan exercise during the week of July 17, 2023. The simulated scenario began with a loose parts alarm in the lower reactor vessel, followed by a high radiation alarm from the reactor coolant system letdown radiation monitor. This met the conditions for declaring a Notice of Unusual Event. Subsequently, a steam generator tube rupture occurred resulting in the loss of reactor coolant system boundary, meeting the conditions for declaring an Alert. As the scenario progressed, a main steam safety valve on the effected steam generator failed open, meeting the conditions for a Site Area Emergency. When off-site field team readings exceeded threshold criteria, conditions for a General Emergency were met, and the Offsite Response Organizations were able to demonstrate their ability to implement emergency actions.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated submitted Emergency Action Level, Emergency Plan, and Emergency Plan Implementing Procedure changes during the week of July 17, 2023. This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) The inspectors observed and evaluated the conduct of an emergency preparedness drill on Unit 1 involving a steam generator tube rupture and a stuck open main steam safety valve resulting in a General Emergency declaration on July 18, 2023.

71114.08 - Exercise Evaluation - Scenario Review

Inspection Review (IP Section 02.01 - 02.04) (1 Sample)

(1) The inspectors reviewed and evaluated in-office, the proposed scenario for the biennial emergency plan exercise prior to the day of the exercise.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===

(1) Unit 1 (July 2022 through June 2023)
(2) Unit 2 (July 2022 through June 2023)

MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)

(1) Unit 1 (January 2022 through December 2022)
(2) Unit 2 (January 2022 through December 2022)

MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)

(1) Unit 1 (January 2022 through December 2022)
(2) Unit 2 (January 2022 through December 2022)

MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)

(1) Unit 1 (January 2022 through December 2022)
(2) Unit 2 (January 2022 through December 2022)

MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1) Unit 1 (January 2022 through December 2022)
(2) Unit 2 (January 2022 through December 2022)

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

(1) Unit 1 (January 2022 through December 2022)
(2) Unit 2 (January 2022 through December 2022)

EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)

(1) July 1, 2022, through March 31, 2023 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
(1) July 1, 2022, through March 31, 2023 EP03: Alert and Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
(1) July 1, 2022, through March 31, 2023

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

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

(1) Potential adverse trend in work hour violations (Corrective Action 11435365)
(2) Adverse trend in the control of transient combustible material (Corrective Action 11441583)

INSPECTION RESULTS

Transient Combustibles Stored in Restricted Areas Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000280,05000281/2023003-01 Open/Closed

[P.3] -

Resolution 71152A The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of License Condition 3.I, Fire Protection, associated with the licensee's failure to implement and maintain in effect, the provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR), which resulted in storage of transient combustibles within restricted or combustion free zones in various areas of Unit 1 and Unit 2.

Description:

Following the NRC issuance of NCV 05000280/2022004-01, Transient Combustible Stored in a Restricted Area, and NCV 05000280,05000281/2023001-01, Transient Combustibles Stored in Restricted Areas, the licensee initiated corrective action assignment (CA) 11894278 regarding an adverse trend of transient combustibles being stored in restricted areas contrary to the requirements of the licensees fire protection program as stated in CM-AA-FPA-101, Control of Combustible and Flammable Materials.

The inspectors reviewed CA11894278, CM-AA-FPA-101, and ETE-SU-2011-0109, Evaluation of Permanently Stored Combustible Material at Surry, and performed a walkdown of plant areas with the site fire marshal to assess whether the corrective actions to address this issue have been effective. In CA11894278, the licensee determined that the most probable cause was that workers and first line supervisors in multiple departments demonstrated a lack of engagement and adherence to the transient fire loading permit requirements to the extent that they did not recognize deviating conditions in the field. The licensee implemented interim corrective actions such as performing a stand down with all site personnel and twice per week walkdowns by site leadership and supervision focusing on transient fire loading permits and general housekeeping. Final corrective actions included designating an independent supervisor to review the work area, upon initial setup, for compliance with program requirements as described in CM-AA-FPA-101; discussing each permit with a member of Site Safety prior to approval to ensure all restrictions are understood; and more frequent reviews of work areas with active transient fire loading permits.

On August 31, 2023, the inspectors conducted a walkdown of plant areas with the site Fire Marshal. During the walkdown, the inspectors identified the following non-compliances with CM-AA-FPA-101, which were determined to be violations of the licensees fire protection program:

  • Fire Zone 4A - Transient combustibles located in the overhead cable tray in the northwest corner of Unit 2 relay room. CM-AA-FPA-101 stated no transient permitted except that required to repair/replace equipment.
  • Fire Zone 4C - Transient combustibles located in Unit 2 Train 2J emergency switchgear room within 3 feet of the Unit 2 containment cable vault Cardox control panel.
  • Fire Zone 45 - Transient combustibles located in mechanical equipment room (MER)-

3 within 10 feet of the south wall.

  • Fire Zone 54 - Transient combustibles located in MER-4. CM-AA-FPA-101, stated that no transient combustibles are allowed in this room.

In addition, on August 10, 2023, during a plant status walkdown of the Unit 1 safeguards/main steam valve house, Fire Zone 19, the inspectors identified transient combustibles behind the safeguards building basement ladder. CM-AA-FPA-101 stated no transients within 10 feet of penetration wall with containment.

The inspectors concluded that the licensees corrective actions to address previous NRC-identified non-cited violations associated with the control of transient combustibles have not been effective.

Corrective Actions: On August 10, 2023, and August 31, 2023, the licensee removed the transient combustibles from the identified restricted areas and initiated condition reports to evaluate corrective actions to address this issue.

Corrective Action References: CR1235281 and CR1236765

Performance Assessment:

Performance Deficiency: The inspectors found that the licensees failure to implement the fire protection program in accordance with licensee procedure CM-AA-FPA-101, which resulted in the storage of transient combustibles within restricted or combustion free zones, was a performance deficiency within the licensees ability to foresee and prevent.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the transient combustible was stored within a restricted or combustion free zone, which affected the zones function to prevent the spread of fire. The inspectors used IMC 0612, Appendix E, Examples of Minor Issues, dated January 1, 2021, to inform answers to the more than minor screening questions and found this condition consistent with more than minor Example 4.j.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. In accordance with IMC 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, the finding was determined to be of very low safety significance (Green) because the fire finding would not increase the likelihood of a fire, delay detection of a fire, or result in a more significant fire than previously analyzed such that the credited safe shutdown strategy could be adversely impacted.

Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, the inspectors found that the licensee did not take effective corrective actions related to two NRC identified findings involving transient combustible stored in restricted areas, which led to an additional finding.

Enforcement:

Violation: License Condition 3.I, Fire Protection, states in part, The licensee shall implement and maintain in effect the provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report UFSAR Section 9.10.1, Design Bases, states in part, Compliance with these criteria is contained in the following documents Fire Protection Program documents and the associated Administrative Procedures describe the administrative and technical controls. Licensee procedure CM-AA-FPA-101, Control of Combustible and Flammable Materials, which includes restrictions for the following areas and states, in part:

  • Fire Zone 4A - Unit 2 relay room: No transient permitted except that required to repair/replace equipment.
  • Fire Zone 4C - Unit 2 train 2J emergency switchgear room: No transient within 3 feet of 1-FP-PNL-HAZ06 and 1-FP-PNL-HAZ08.
  • Fire Zone 19 - Unit 1 safeguards/main steam valve house: No transient within 10 feet of penetration wall with containment.
  • Fire Zone 45 - MER-3: No transient permitted within 10 feet of the south wall (MER#4) or west wall (U2ESGR/battery room).
  • Fire Zone 54 - MER-4: No transient permitted.

Contrary to the above, prior to August 10, 2023 (Fire Zone 19), and prior to August 31, 2023 (Fire Zones 4A, 4C, 45, and 54), the licensee failed to implement and maintain in effect, the provisions of the approved fire protection program as described in the UFSAR, resulting in noncompliance with the fire protection combustible control program as documented CM-AA-FPA-101. Specifically, the licensee stored transient combustibles within restricted or combustion free zones noted above.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

  • On October 16, 2023, the inspectors presented the integrated inspection results to David Wilson, Site Vice President, and other members of the licensee staff.
  • On July 20, 2023, the inspectors presented the emergency preparedness exercise inspection results to David Wilson, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CR1179951

ANS Evaluation Report

10/22/2022

CR1182798

NRC ENS line is non-functional

10/15/2021

CR1209676

Offsite Notifications

10/06/2022

CR1223366

RP below ERO minimum shift manning requirements

4/5/23

CR1224246

State and Local Comm selected 'Emergency' vs. 'Drill' on

ENF

4/12/2023

CR1228173

TSC UPS failed to transfer to its normal source

5/12/23

Corrective Action

Documents

CR1231023

Unexpected response in MIDAS during drill

6/15/23

Surry Emergency Plan

Rev. 72

0-AP-37.00

Seismic Event

0-LSP-J-W-001

Early Warning System Polling Functional Test

1/11/2022

EPIP 3.03

ACTIVATION OF OPERATIONAL SUPPORT CENTER

Rev. 27

EPIP-1.01

Emergency Manager Controller Procedure

EPIP-1.01

Emergency Manager Controlling Procedure

Rev. 63

EPIP-1.02

Response to Notification of Unusual Event

EPIP-1.03

Response to Alert

EPIP-1.04

Response to Site Area Emergency

EPIP-1.05

Response to General Emergency

EPIP-1.06

Protective Action Recommendations

EPIP-1.06

Protective Action Recommendations

EPIP-2.01

Notifications and Communications

EPIP-2.02

Notification of NRC

EPIP-3.02

Activation of the TSC

EPIP-3.06

Corporate Emergency Response Center Activation

Rev. 2

EPIP-3.10

CERC Technical Support Controlling Procedure

EPIP-4.01

Radiological Assessment Director Controlling Procedure

EPIP-4.02

Radiation Protection Supervisor Controlling Procedure

EPIP-4.03

Dose Assessment Team Controlling Procedure

EPIP-4.04

Emergency Personnel Radiation Exposure

EPIP-4.07

Protective Measures

71114.01

Procedures

EPIP-4.09

Source Term Assessment

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

EPIP-4.15

Onsite Monitoring

EPIP-4.34

Field Team Radio Operator Rev 10

EPIP-5.01

Transportation of Contaminated Injured Personnel

EPIP-5.03

Personnel Accountability

Rev. 26

EPIP-5.09

Attacks Against Station, Security Threat or Security

Condition

SU-22-01-0

50.54(q) Change Package for SPS EAL Matrix and EAL

Technical Basis Document

SU-22-02-0

50.54(q) Change Package for Surry LBCDR 463

1/18/22

SU-22-03-0

50.54(q) Change Package for EPIP 3.02 Activation of the

TSC

SU-22-05-0

50.54(q) Change Package for SPS EAL Matrix and EAL

Technical Basis Document

SU-22-06-0

50.54(q) Change Package for EPIP-4.34 Field Team Radio

Operator Rev 10

SU-22-07-0

50.54(q) Change Package for EPIP-3.10 CERC Technical

Support Controlling Procedure

SU-22-08

50.54(q) Change Package for EPIP-1.06 Protective Action

Recommendations

SU-22-09-0

50.54(q) Change Package for EPIP-3.03 Activation of the

OSC

SU-22-11-0

50.54(q) Change Package for EPIP-4.07 Protective

Measures

SU-23-01-0

50.54(q) Change Package for EPIP-5.01 Transportation of

Contaminated Injured Personnel

SU-23-02-0

50.54(q) Change Package for EPIP-1.01 Emergency

Manager Controller Procedure

SU-23-03-0

Update to EPIP-4.03, Dose Assessment Team Controlling

Procedure - EPIP-4.03, Rev. 24

2/08/2023

SU-23-04-0

EPIP-5.09 Attacks Against Station, Security Threat or

Security Condition

SU-23-05-0

50.54(q) Change Package for 0-AP-37.00 Seismic Event

71114.04

Miscellaneous

SU-23-06-0

50.54(q) Change Package for EPIP-4.01 Radiological

Assessment Director Controlling Procedure

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

SU-23-07-0

50.54(q) Change Package for EPIP-4.02 Radiation

Protection Supervisor Controlling Procedure

SU-23-08-02

50.54(q) Change Package for EPIP-4.04 Emergency

Personnel Radiation Exposure

SU-23-09-01

50.54(q) Change Package for EPIP-4.09 Source Term

Assessment

SU-23-10-0

50.54(q) Change Package for EPIP-4.15 Onsite Monitoring

SU-23-11-1

50.54(q) Change Package for EPIP-4.16 Offsite Monitoring

SU-23-12-0

50.54(q) Change Package for EPIP-4.34 Field Team Radio

Operator Rev 10

SU-23-13-0

50.54(q) Change Package for 0-LSP-CO-005 Rev 2

6/26/23

EAL

Surry Power Station Emergency Action Level Matrix

Rev. 6

Procedures

EAL

Surry Power Station Emergency Action Level Matrix

Rev. 7

Corrective Action

Documents

CR1225406

Unsuccessful DEP opportunity from 4/4/2023 drill (CERC)

4/21/2023

Miscellaneous

2nd quarter 2022 through 1st quarter 2023 PI data.

71151

Procedures

EP-AA-103

Emergency Preparedness Performance Indicators

Rev. 11