IR 05000280/2022010

NRC Inspection Report 05000280/2022010 and 05000281/2022010

ML22070A972
Person / Time
Site:	Surry
Issue date:	03/15/2022
From:	James Baptist NRC/RGN-II/DRS/PSB1
To:	Stoddard D Virginia Electric & Power Co (VEPCO)
Fanelli T
References
IR 2022010
Download: ML22070A972 (15)

Text

March 15, 2022

SUBJECT:

SURRY POWER STATION - NRC INSPECTION REPORT 05000280/2022010 AND 05000281/2022010

Dear Mr. Stoddard:

On February 4, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Surry Power Station and discussed the results of this inspection with James Holloway 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. 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, James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety Docket Nos. 05000280 and 05000281 License Nos. DPR-32 and DPR-37 Enclosure:

NRC Inspection Report (IR) 05000280/2022010, 05000281/2022010 w/attachment: Appendix G Phase II Screening Signed by Baptist, James on 03/15/22

ML22070A972 x Non-Sensitive x Publicly Available x SUNSI Review Sensitive Non-Publicly Available

OFFICE RII:DRS RII:DRS RII:DRS RII:DRS NAME T. Fanelli C. Franklin C. Cauffman J. Baptist DATE 3/14/22 3/2/22 3/2/22 3/15/22

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Numbers: 05000280 and 05000281

License Numbers: DPR-32 and DPR-37

Report Numbers: 05000280/2022010 and 05000281/2022010

Licensee: Virginia Electric and Power Company

Facility: Surry Power Station

Location: Surry, VA.

Inspection Dates: January 31, 2022 to February 04, 2022

Inspectors: C. Cauffman, Reactor Operations Engineer T. Fanelli, Senior Reactor Inspector C. Franklin, Reactor Inspector

Approved By: James B. Baptist, Chief Engineering Br 1 Division of Reactor Safety

Enclosure

SUMMARY

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

List of Findings and Violations

Failure to Verify DC Crosstie Design Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.17T Systems NCV 05000280,05000281/2022010-01 Open/Closed The inspectors identified a Green finding and an associated NCV of 10 CFR 50 Appendix B Criterion III, Design Control, for the licensee's failure to verify that DC train crosstie circuits were qualified to perform the required safety function and not fail under normal and design basis events specified by the postulated phenomena as outlined in IEEE 308-1974.

Additional Tracking Items

None.

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 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

71111.17T - Evaluations of Changes, Tests, and Experiments Sample Selection (IP Section 02.01)

The inspectors reviewed the following evaluations, screenings, and/or applicability determinations for 10 CFR 50.59 from 1/31/2022 to 2/4/2022.

(1) DCP-00-042, CW Canal Level Probe Missile Shield Replacement

(2) DCP-02-029, FAC U1 Piping Replacement

(3) DCP-04-051, RCP DP Transmitter Replacement

(4) DCP-04-100, Replace Circuit Breakers and Verify Thermal Overload Settings for Control Room and Emergency Switchgear Room Air Handlers

(5) DCP-05-025, Outside Recirculation Spray (ORS) Pump Test Loop Modifications

(6) DCP-06-045, SW Carbon Steel Piping Replacement with Copper-Nickel

(7) DCP-99-093, Replacement of Control Room Recorders with Paperless Recorders

(8) SU-09-0036, Recirc Spray Heat Exchanger Service Water Monitoring System

(9) SU-13-01053, EDG Data Acquisition System Quick Connect and Test Setup

(10) SU-15-00006, Risk Release Reactor Coolant Pump 1-RC-P-1B Seal Face Change

(11) SU-16-00108, Surry Unit 2 AFW MOV Hot Short Resolution

(12) SU-16-00109, Surry Unit 1 AFW MOV Hot Short Resolution

(13) SU-16-00115, Replacement/Modification of Two Pipe Supports on The Unit 2 Safety Injection System

(14) SU-16-01064, DC Crosstie and UPS Feeder Circuit Breaker Replacement

(15) SU-17-00104, MOV Hot Short MCC Wiring Modification

(16) SU-18-00116, Stem and Disc Arm Replacement For 1-SI-MOV-1863a

(17) SU-18-00173, Reconfiguration of U2 Pressurizer Heaters, 10, 33, and 50

(18) SU-19-00110, "A" RCP Floating Ring Seal Removal

(19) SU-21-00135, 1-RC-HCV-1556A & C-Valve Spring Hanger Support Modification

(20) SU-17-00123, Installation of Swagelok Fittings on 2-SS-PP-0.38-Pipe

(21) SU-09-00046, Turbine Supervisory Instrumentation Replacement

(22) SU-13-00008, 18" CC-229-121 And 18" CC-235-121 Repairs

(23) SU-18-00160, VFD Swap for 1-LW-P-12/13

(24) SU-19-00156, Modify 8"-CC-70-151 Hanger

(25) SU-18-00159, Temp Mod, Temporary Modification CERPI System Shutdown Bank A No7 and Position Indication Detector Secondary Winding Resistance Signal

(26) SU-17-00122, Reconfigure Unit 2 Pressurizer Heaters

(27) SU-19-00134, 2020 Unit 2 FAC Modifications

INSPECTION RESULTS

Failure to Verify DC Crosstie Design Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.17T Systems NCV 05000280,05000281/2022010-01 Open/Closed The inspectors identified a Green finding and an associated NCV of 10 CFR 50 Appendix B Criterion III, Design Control, for the licensee's failure to verify that DC train crosstie circuits were qualified to perform the required safety function and not fail under normal and design basis events specified by the postulated phenomena as outlined in IEEE 308-1974.

Description:

Design Change No. SU-16-01064 replaced the DC crosstie molded case circuit breakers (MCCBs) in Unit 1 (1A-22 and 1B-21) and Unit 2 (2B-19 and 2A-22). The existing two-pole MCCBs, NB21200F, were replaced with three-pole MCCBs, HNB31200F. The manufacturer catalog, No. V12-T3-43, specified that, DC qualified MCCBs including the trip units are, two-pole breakers supplied in three-pole frames with current carrying parts omitted from center pole. Three-pole MCCBs and trip units were specified as AC only, [Alternating Current only]. The DC ratings were not applicable. The purchase order (PO) No. 4500398109 ordered 250 vac, 1200 amps, model HNB31200F with unit, magnetic trip, adjustable, model HNB312000TM. Not, DC qualified MCCBs. The PO neither specified the actual DC application requirements nor the required DC amperes of interrupting capacity (AIC). The HNB type MCCBs do not appear to have been formally qualified for the designs required AIC of more than 19,000A. The listed Underwriters Laboratory DC ratings for the two-pole HNB MCCBs was just 10,000A. Further, the design required one of the MCCBs to be in a reverse current flow condition while cross tied. The Eaton HNB Application Data,29-160, states, in part, that the NB and HNB breakers can be mounted in an inverted position but are not approved for reverse feed. This could further adversely affect the AIC rating of the MCCB. The inspectors determined that the MCCBs were not designed to clear a fault and withstand the available short circuit currents in the DC crosstie design.

One of the applicable licensing basis design standards, Institute of Electrical and Electronics Engineers (IEEE) 308-1974, section 4.1, General. stated, the Class 1E power systems shall be designed to assure that no design basis event will cause:

(1) A loss of electric power to a number of engineered safety features, surveillance devices, or protection system devices sufficient to jeopardize the safety of the station, and

(2) A loss of electric power to equipment that could result in a reactor power transient capable of causing significant damage to the fuel or to the reactor coolant system. And, Section 4.7, Equipment Qualification. stated each type of Class 1E power equipment shall be qualified by analysis, successful use under similar conditions, or by actual test to demonstrate its ability to perform its function under normal and design basis events. The design basis events specified included, in part, the following postulated phenomena: Fires; Fire-protection system operation; Accident generated flooding, sprays, or jets; Postulated loss of the preferred power supply combined with any of the above; Single equipment malfunction; Single act, event, component failure, or circuit fault that can cause multiple equipment malfunctions; and a Single equipment maintenance outage.

The inspectors determined that the HNB circuit breakers were not qualified to crosstie the two Class 1E DC trains while preventing a loss of electric power as specified in the design standard.

Corrective Actions: The licensee entered this issue into the corrective action program and placed danger/warning tags on the circuit breakers to prevent their use during outage operations.

Corrective Action References: CR1190494

Performance Assessment:

Performance Deficiency: The licensing basis design standard IEEE 308-1974, required Surry to ensure that each type of Class 1E power equipment shall be qualified to demonstrate its ability to perform its function under normal and design basis events as specified by the postulated phenomena. The failure to verify that DC train crosstie circuits were qualified to perform the required safety function and not fail under normal and design basis events specified by the postulated phenomena as outlined in IEEE 308-1974 was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control 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 performance deficiency could cause a loss of DC power to both trains causing a loss of required mitigating systems.

Significance: The inspectors assessed the significance of the finding using Appendix G, Shutdown Safety SDP. The inspectors initial Phase I screening required a phase II SDP to be performed. Attached is the completed SDP IMC 0609 Appendix G, attachment 2, Phase II screening completed by a Region II SRA, which characterizes this finding as GREEN.

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Title 10 CFR 50, Appendix B, Criterion III, "Design Control," required, in part, "design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program."

Contrary to the above, the licensee failed to provide design control measures for verifying or checking the adequacy of the DC train crosstie circuit design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. Specifically, the licensee failed to verify that DC train crosstie circuits were qualified to perform the required safety function and not fail under normal and design basis events specified by the postulated phenomena as outlined in IEEE 308-1974.

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 February 4, 2022, the inspectors presented the NRC inspection results to James Holloway and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.17T Calculations 01039.0810-E-Cable Sizing for 480V MCC Loads Related to DCP 90-15-3 0-00A

011

2846.36-NPB-Pipe Stress Analysis Problem 4093 of The Service Water 4

4093-X12 System

2846.39-NPN-Pipe stress evaluation of line 8"-WS-489-21X as the class of 1

4091-X12 the piping changed from 151 (Carbon steel) to 21X (Cu-Ni) per

DCP 06-045, SPS 2.

14937.53-NPB-Pipe Stress Analysis: Service Water Piping In Valve Pit, Lines 0

007-XE 8"-WS-481, 482-21X Turbine / Service Building

EE-0499 DC Vital Bus Short Circuit Current 2

ME-0791 Sizing of ORS Pump Test Loop Piping 0

SU-CALC-PSP-Safety Injection - Show Cause Support/Restraint & Baseplate 5

2681

Drawings S-05025-2-Flow/Value Operating Numbers Diagram Recirculation Spray 2

2FM084B System Surry Power Station Unit 2 Virginia Power

Engineering DC-02-029 2003 FAC U1 Replacement / Surry/ Unit 1 11/07/2002

Changes DCP SU-18-Design Equivalent Change Package 1

00116

SU-06-045 SW Carbon Steel Piping Replacement with Copper-Nickel / 03/12/2007

Surry / Units 1 & 2

SU-09-00046 Turbine Supervisory Instrumentation Replacement I Surry I 01/21/2010

Unit I

SU-09-0036 Recirc Spray Heat Exchanger Service Water Monitoring 04/22/2010

System

SU-13-00008 18" CC-229-121 and 18" CC-235-121 Repairs 07/15/2013

SU-15-00006 Risk Release Reactor Coolant Pump 1-RC-P-1B Seal Face 07/15/2015

Change

SU-16-00115 Replacement/Modification of two pipe supports on the Unit 2 3

Safety Injection System

SU-17-00122 Reconfigure Unit 2 Pressurizer Heaters 0

SU-17-00123 Installation of Swagelok Fittings on 2-SS-PP-0.38-SS-PIPE-1

304-1CN9

Inspection Type Designation Description or Title Revision or

Procedure Date

SU-18-00159 Temporary Modification CERPI System Shutdown Bank A N07 0

Rod Position Indication Detector Secondary

Winding Resistance Signal

SU-19-00110 "A" RCP Floating Ring Seal Removal 1

SU-19-00156 Modify 8" CC-70-151 Hanger 0

SU-21-00135 1-RC-HCV-1556A & C-Valve Spring Hanger Support 0

Modification

SU-DCP-000-38-Replace Circuit Breakers and Verify Thermal Overload 03/01/2005

DCP-04-100 Settings for Control Room and

Emergency Switchgear Room Air Handlers/Surry/Unit 1 & 2

SU-DCP-000-38-ORS Pump Test Loop Modification/Surry/Unit2 04/27/2006

DCP-05-025

TM S2-17-150 Reconfiguration of Pressurizer Heaters 0

Engineering DC-SU-15-00006 50.59/72.48 Screen 7/15/15

Evaluations SU-09-00046 50.59/72.48 Screen 01/06/2010

SU-13-01053 EDG Data Acquisition System Quick Connect and Test Setup 14

SU-13-01053 50.59/72.48 Screen 0

SU-18-00116 Stem and Disc Arm Replacement for 1-SI-MOV-1863A 1

SU-19-00110 50.50/72.48 Screen 1

SU-19-00156 Design Equivalent Change Package

Miscellaneous Eaton 27.3-43 Molded-Case Circuit Breakers & Enclosures, Application Data, 04/01/2016

Table 27.3-13. Reverse-Feed ApplicationsEatons Circuit

Breakers

Eaton Application AB DE-ION Circuit Breakers, Standard Type NB, and MARK 12/01/1988

Data 29-160 75 700-1200 Amperes, 600 Volts Ac, 250 Volts Dc,CD 2 and

Poles Type NBY 240 Volts Ac, 700-1200 Amperes

Eaton Catalog Molded-Case Circuit Breakers, Volume 12, Aftermarket, 02/01/2019

V12-T3-1 Renewal Parts and Life Extension Solutions

EP-0026 Surry Unit 1, 2003 Refueling Outage Results of Secondary 0

Piping & Component Inspection Program

IEEE Standard IEEE Standard Criteria for Class 1E Power Systems for 03/14/1975

308-1974 Nuclear Power Generating Stations

Licensee Surry Power Station - 10CFR 50.59 Inspection Supplemental 02/09/2022

Response Information on DC Cross Tie Breakers

Inspection Type Designation Description or Title Revision or

Procedure Date

SU-PO-MAT-Incoming Insp. for GR for Purchase Order 0

4500398109-

00002-

000000264325

_42276061

Procedures 1K-A6, Batt Bus Tie Bkr Closed 3

1A/1B

2K-A6, Batt Bus Tie Bkr Closed 1

1A/1B

ER-AA-FAC-1001 Flow-Accelerated Corrosion (FAC) Susceptibility Analysis & 6

Modeling

ER-AA-FAC-1003 Flow-Accelerated Corrosion (FAC) Operational Experience 6

Reviews

ER-AA-FAC-102 Flow-Accelerated Corrosion (FAC) Inspection and Evaluation 1

Activities

ER-AA-FAC-104 Crossover/Crossunder Inspection & Evaluation Activities 1

STD-GN-0033 Secondary Piping and Component Inspection Program 9

SU-PROC-000-1-Removal from Service and Return to Service of Station Battery 16

MOP-EP-030 1A

SU-PROC-000-1-Removal From Service And Return To Service Of Station 16

MOP-EP-031 Battery 1B

VPAP-0807 Secondary Piping and Component Inspection Program 2

Work Orders 00524235 02 Replace Circuit Breakers and Verify Thermal Overload 02/20/2006

Settings Control Room and Emergency Switch Gear Air

Handlers

00524235 03 Replace Circuit Breakers and Verify Thermal Overload 02/20/2006

Settings Control Room and Emergency Switch Gear Air

Handlers

38077408903,

38077408902,

38072198008,

00774089-01,

00721980-01

IMC 0609 Appendix G Phase II Screening

Performance Deficiency: The licensing basis design standard IEEE 308-1974, required Surry to

ensure that each type of Class 1E power equipment shall be qualified to demonstrate its ability

to perform its function under normal and design basis electrical failure events. The failure to

ensure that the DC crosstie circuit breakers could meet the fault duty required by the design

basis electrical failure events was a performance deficiency.

Safety Consequence: DC breakers will not provide fault protection as designed and could result

in an unrecoverable Loss of All DC as the fault would not be cleared/isolated and both DC

buses would be damaged and not be recoverable. DC bus cross connection is only allowed in

Mode 5 by Tech Specs. Loss of DC power would remove all Control Power for Pumps and

Valves and remove all remote indications and alarms.

Note: Procedure 1-MOP-EP-030, Removing 1A Battery may only be performed in Refueling

shutdown (POS III), however 1-MOP-EP-031, Removing 1B Battery may be performed in Cold

shutdown or refueling shutdown (POS I, POS II, or POS III). DC buses being cross connected

is limited to 7 days due to a TS LCO for the non-outage unit

Bottom Line Screen to Green in phase II, may re-exit with a Green NCV. Since the report was

not issued no SDP clocks were started for the TBD AV.

ANALYSIS

1. This is a Conditional Finding so IELs from IMC 0609 Appendix G Attachment 2 Table 5,

Initiating Even Likelihoods (IELs) for Condition Findings - PWRs. Assume exposure

period of 7 days (column 2)

LOOP 2

LORHR 2

LOI 3

LOLC 2 (2 for all exposure periods)

2. Use the DC bus Faulting basic event from the SPAR Model DCP-BDC-LP-1A (B)

(FAILURE OF 125V DC BUS 1A (B)) = 5.108 E-6 events/year

3. IEL for DC bus failure during exposure period: (DCP-BDC-LP-1A OR DCP-BDC-LP-1B)

x exposure time = (5.108 E-6 + 5.108 E-6) x (7/365) = 1.9E-7

4. Conditional so Add IEL + IE for DC Bus Failure to get Conditional IEL

LOOP 2 + 7 = 9

LORHR 2 + 7 = 9

LOI 3 + 7 = 10

LOLC 2 +7 =9

5. IMC 0609 Appendix G Attachment 2 worksheets 1-7 are applicable for shutdown

initiating event LOLC, LOOP, and LOI in a 3 Loop Westinghouse PWR. Worksheets 8

and 9 are used for a LORHR for a 4 loop Westinghouse plant. (Conservatively used in

this case despite it being a 3 loop Westinghouse)

6. Worksheet 1 LOLC POS I

a. LOLC-SG-RHR-R-RWSYMU - 9

b. LOLC-SG-Feed & Bleed - 9

7. Worksheet 2 LOLC POS II

a. LOI-RHR-R-RWSTMU - 10

b. LOI-Feed - 10

8. Worksheet 3 LOOP POS I

a. LOOP-EAC-SGSBO-RLOOP3 -9 + 1 = 10

9. Worksheet 4 LOOP POS II

a. LOOP-EAC-RLOOP18 - 9 + 1 =10

b. LOOP-EAC-Gravity-RLOOP4 - 9 + 1 = 10

10.Worksheet 5 LOI POS I

a. LOI-SG-RHR-R-RWSTMU - 10

b. LOI-SG-BLEED -10

c. LOI-LEAKSTOP-RWSTMU -10

d. LOI--FEED-SG - 10

e. LOI-FEED-LEAKSTOP -10

11.Worksheet 6 LOI POS II

a. LOI-RHR-R-RWSTMU - 10

b. LOI-LEAKSTOP-RWSTMU-10

c. LOI-FEED -10

2.Worksheet 7 LOI POS III

a. LOI-RHR-R -10

b. LOI-RHR-LEAKSTOP-10

c. LOI-FEED-10

13.Worksheet 8 LORHR POS I

a. LORHR - RHR-S - SG - RHR-R-RWSTMU -9

b. LORHR - RHR-S - SG - FEED&BLEED - 9

14.Worksheet 9 LORHR -POS II

a. LORHR - RHR-S - RHR-R - RWSTMU - 9

b. LORHR - RHR-S - FEED - 9

Totals

1-MOP-EP-031 (B Battery disconnected) (POS I, II, and III )

x 10

x 9

Counting Rule:

10s: 16/3 (round down)=5

9s: (6+5)/3 (round down)=3

8s: (3+2)/3 (round down) = 1

7s: (0+1)/3 (round down =0

6s: 0 therefore GREEN

1-MOP-EP-030 (A Battery disconnected) (POS III only)

X 10

Counting Rule:

10s 3/3 (round down) = 1

9s (1+0)/3 (round down) =0

8s: 0

7s: 0

6s: 0 therefore Green

3