IR 05000348/2017002

Joseph M. Farley Nuclear Plant - NRC Integrated Inspection Report 2017-002 and Exercise of Enforcement Discretion

ML17216A057
Person / Time
Site:	Farley
Issue date:	08/04/2017
From:	Munday J T Division Reactor Projects II
To:	Madison D R Southern Nuclear Operating Co
References
EA-17-131 IR 2017002
Download: ML17216A057 (34)

Text

August 4, 2017

EA-17-131

Dennis R. Madison, Vice President Southern Nuclear Operating Company, Inc.

Joseph M. Farley Nuclear Plant 7388 North State Highway 95 Columbia, AL 36319

SUBJECT: JOSEPH M. FARLEY NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000348/2017002 AND 05000364/2017002; AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Madison:

On June 30, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Joseph M. Farley Nuclear Plant, Units 1 and 2. On July 27, 2017, NRC inspectors discussed the results of this inspection with Mr. John Horn and other members of your staff. The results of this inspection are documented in the enclosed report.

Section 1R22 of the enclosed report discusses a finding with an associated apparent violation for which the NRC has not yet reached a preliminary significance determination. This finding involved a failure to implement corrective maintenance work order instructions to identify and replace a degraded jacket water fitting on the 2B Emergency Diesel Generator (EDG) jacket water keep warm system piping.

We intend to issue our final safety significance determination and enforcement decision, in writing, within 90 days from the date of this letter. The NRC's significance determination process (SDP) is designed to encourage an open dialogue between your staff and the NRC; however, neither the dialogue nor the written information you provide should affect the timeliness of our final determination. We ask that you promptly provide any relevant information that you would like us to consider in making our determination. We are currently evaluating the significance of this finding and will notify you in separate correspondence once we have completed our preliminary significance review. You will be given an opportunity to provide additional information prior to our final significance determination unless our review concludes that the finding has very low safety significance (i.e., Green).

NRC inspectors documented two findings of very low safety significance (Green) in this report. Both of these findings involved violations of NRC requirements. The NRC is treating these violation as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy. In addition, there is a violation for which the NRC will exercise enforcement discretion. A violation of 10 CFR Part 50, Appendix A, Criterion 2, for tornado-generated missile protection for the service water intake and exhaust ventilation hoods and the emergency diesel generator fuel oil storage tanks was identified. Because this violation was identified during the discretion period covered by enforcement Guidance Memorandum 15-002, "Enforcement Discretion for Tornado Missile Protection Noncompliance," and because the licensee was implementing compensatory measures, the NRC is exercising enforcement discretion by not issuing an enforcement action for the violation and allowing continued reactor operation.

If you contest the violations or significance of these NCVs, 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 the Joseph M. Farley Nuclear Plant, Units 1 and 2.

If you disagree with a cross-cutting aspect assignment you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC resident inspector at the Joseph M. Farley Nuclear Plant, Units 1 and 2.

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

Sincerely,/RA/

Joel T. Munday, Director Division of Reactor Projects Docket Nos.: 50-348, 50-364 License Nos.: NPF-2, NPF-8

Enclosure:

IR 05000348/2017002, 05000364/2017002

w/Attachment:

Supplemental Information cc Distribution via ListServ

SUMMARY

IR 05000348/2017002; and 05000364/2017002, April 1, 2017 through June 30, 2017; Joseph M. Farley Nuclear Plant, Units 1 and 2, Operability Determinations and Functionality

Assessments; Surveillance Testing; Maintenance of Emergency Preparedness

The report covered a 3-month period of inspection by resident inspectors and regional inspectors. There is one apparent violation (AV) and two non-cited violations (NCV) documented in this report. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP) dated April 29, 2015.

The cross-cutting aspects are determined using IMC 0310, "Aspects within the Cross-Cutting Areas" dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy dated November 1, 2016. The NRC's program for overseeing the safe operations of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6. Documents reviewed by the inspectors which are not identified in the Report Details are identified in the List of Documents Reviewed section of the Attachment.

Cornerstone: Barrier Integrity

Green.

The NRC identified a Green non-cited violation (NCV) of Technical Specification (TS) 5.4.1.a, "Procedures," when inspectors found the 1A containment spray (CS) pump room door (door 106) open on May 12, 2017, without the required dedicated individual to close the door. As a result, the penetration room filtration (PRF) system boundary was inoperable which rendered both trains of the PRF system inoperable. Failure to follow section 19.0 of licensee procedure FNP-0-SOP-0.0, Version 163, was a performance deficiency.

The performance deficiency was more than minor because it was associated with the structure, system, component and barrier performance attribute of the barrier integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, when door 106 was open, the PRF system boundary was inoperable, which caused both PRF trains to be inoperable. Without the dedicated individual to close the door as directed, the ability of the PRF system to perform its safety function was compromised. The significance of this finding was evaluated using IMC 0609, Appendix A, "The Significance Determination Process (SDP) for Findings At-Power," dated June 19, 2012. This finding was of very low safety significance (Green) because the finding only represented a degradation of the radiological barrier function provided for the auxiliary building through the PRF system. The inspectors determined the finding had a cross-cutting aspect of Teamwork in the Human Performance area because maintenance did not effectively communicate and coordinate their activities with operations to ensure the requirements were met when door 106 was left open [H.4]. (Section 1R15)

Cornerstone: Mitigating Systems

• To Be Determined (TBD). The NRC identified an apparent violation (AV) of Technical Specification (TS) 5.4.1.a, "Procedures," for the licensee's failure to implement corrective maintenance work order instructions to identify and replace a degraded jacket water fitting on the 2B emergency diesel generator (EDG) jacket water keep warm system piping. As a result, a leak occurred on the 2B EDG jacket water piping system during surveillance testing which rendered the EDG inoperable.

3 The inspectors determined that the failure to follow work order instructions to replace degraded jacket water system piping during corrective maintenance on the 2B DG on March 3, 2017, was a performance deficiency. The finding was more than minor because it was associated with the equipment reliability attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

The significance of this finding was evaluated using IMC 0609, Appendix A, "The Significance Determination Process (SDP) for Findings At-Power," dated June 19, 2012. Initial screening by the resident inspectors using the Sapphire Farley 1 & 2 SPAR Model resulted in a potentially greater-than-green significance. Therefore, a detailed risk analysis will be performed by a regional senior reactor analyst (SRA). The inspectors determined the finding had a cross-cutting aspect of Conservative Bias in the Human Performance area, because the decision to leave the diesel in a degraded condition following maintenance was neither conservative nor prudent when additional action could have been taken to adequately repair or evaluate the piping connection [H.14]. (Section 1R22)

Cornerstone: Emergency Preparedness

Green.

A self-revealing Green NCV of Title 10 of the Code of Federal Regulations (CFR) Part 50.54(q)(2), Part 50.47(b)(4), and Appendix E,Section IV.C.2, was identified for the failure to declare a Notification of Unusual Event (NOUE), during an actual event.

Specifically, on November 1, 2016, Farley Unit 1 experienced conditions that met Emergency Action Level (EAL) HU3, Release of Toxic, Asphyxiant, or Flammable Gases Deemed Detrimental to Normal Operation of the Plant. The failure to declare a NOUE during an actual event was considered a performance deficiency. This finding was more than minor because it was associated with the Emergency Preparedness cornerstone attribute of Emergency Response Organization Performance (actual event response), and adversely affected the cornerstone objective of ensuring that a licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, on November 1, 2016, Farley Unit 1 experienced conditions that met EAL HU3 for declaring a NOUE when toxic gas (ammonia) was detected in a vital area, which is also part of the owner controlled area.

The performance deficiency is associated with the Emergency Classification Planning Standard 10 CFR 50.47(b)(4) and Appendix E Section IV.C.2, and is considered a Risk Significant Planning Standard (RSPS). The failure to declare a NOUE when directed by the EAL Matrix is considered a lost or degraded RSPS in accordance with Section 4 of Inspection Manual Chapter (IMC) 0609, Appendix B. Section 4.3.e of IMC 0609,

Appendix BProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix B" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., provides the significance determination for a "Failure to Implement," and the performance deficiency was determined to be of a low safety significance (Green). The finding was also determined to be associated with a cross-cutting aspect in the Training component of the Human Performance area because the organization did not provide adequate training to the various ERO members involved in this event to ensure knowledge transfer to maintain a knowledgeable, technically competent workforce, and instill nuclear safety values [H.9]. (Section1EP5)

REPORT DETAILS

Summary of Plant Status Unit 1 maintained approximately 100 percent rated thermal power (RTP) throughout the report period.

Unit 2 maintained approximately 100 percent RTP throughout the report period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

a. Inspection Scope

Summer Readiness of Offsite and Alternate AC Power System: The inspectors reviewed the licensee's procedures for operation and continued availability of offsite and onsite alternate AC power systems. The inspectors also reviewed the communications protocols between the transmission system operator and the licensee to verify that the appropriate information is exchanged when issues arise that could affect the offsite power system. The inspectors reviewed the material condition of offsite and onsite alternate AC power systems (including switchyard and transformers) by performing a walkdown of the switchyard on June 14, 2017.

Documents reviewed are listed in the Attachment.

Readiness for Impending Adverse Weather Conditions: The inspectors reviewed the licensee's preparations to protect risk-significant systems from adverse weather conditions expected during a Severe Thunder Storm Warning and a Tornado Watch on April 3, 2017. The inspectors evaluated the licensee's implementation of adverse weather preparation procedures and compensatory measures, including operator staffing, before the onset of the adverse weather conditions. The inspectors verified that operator actions specified in the licensee's adverse weather procedure maintain readiness of essential systems. The inspectors also verified that the licensee implemented periodic equipment walkdowns or other measures to ensure that the condition of plant equipment met operability requirements.

b. Findings

No findings were identified.

1R04 Equipment Alignment

a. Inspection Scope

Partial Walkdown: The inspectors verified that critical portions of the following systems were correctly aligned by performing partial walkdowns. The inspectors determined the correct system lineup by reviewing plant procedures and drawings listed in the

.

• Unit 1, Residual Heat Removal (RHR) System, "B" Train

• Unit 1, "1B" Diesel Generator (DG)

• Unit 1, "1B" Containment Spray Pump

• Units 1 & 2, Common Main Control Room AC and Emergency Filtration System - "A" Train

b. Findings

No findings were identified.

1R05 Fire Protection

a. Inspection Scope

Quarterly Inspection: The inspectors evaluated the adequacy of fire plans by comparing the fire plans to the defined hazards and defense-in-depth features specified in the fire protection program for the following four fire areas.

• Unit 2, Room 2210 - Corridor, Fire Area 2-020, Fire Zone 2210

• Unit 2, Room 2211 - Corridor, Fire Area 2-020, Fire Zone 2211

• Unit 2, Room 2228 - Corridor, Fire Area 2-020, Fire Zone 2228

• Unit 2, Room 2234 - Hallway, Fire Area 2-020, Fire Zone 2234 The inspectors assessed the following:

• control of transient combustibles and ignition sources

• fire detection systems

• water-based fire suppression systems

• gaseous fire suppression systems

• manual firefighting equipment and capability

• passive fire protection features

• compensatory measures and fire watches

• issues related to fire protection contained in the licensee's corrective action program

• material condition and operational status of fire protection equipment Fire Drill Observation: The inspectors observed the licensee's fire brigade performance during a fire drill on April 6, 2017, and assessed the brigade's capability to meet fire protection licensing basis requirements. The inspectors observed the following aspects of fire brigade performance:

• capability of fire brigade members

• leadership ability of the brigade leader

• proper use of turnout gear and fire-fighting equipment

• team effectiveness

• compliance with site procedures The inspectors also assessed the ability of control room operators to combat potential fires including identifying the location of the fire, dispatching the fire brigade, and sounding alarms. The inspectors evaluated the licensee's ability to declare the appropriate emergency action level and make required notifications.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

a. Inspection Scope

Resident Inspector Quarterly Review of Licensed Operator Requalification: The inspectors observed an evaluated simulator scenario administered to an operating crew as part of the annual requalification operating test required by 10 CFR 55.59, "Requalification." The inspectors assessed the following:

• licensed operator performance

• the ability of the licensee to administer the scenario and evaluate the operators

• the quality of the post-scenario critique

• simulator performance

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors assessed the licensee's treatment of the two issues listed below to verify the licensee appropriately addressed equipment problems within the scope of the maintenance rule (10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants"). The inspectors reviewed procedures and records to evaluate the licensee's identification, assessment, and characterization of the problems as well as their corrective actions for returning the equipment to a satisfactory condition. The inspectors also interviewed system engineers and the maintenance rule coordinator to assess the accuracy of performance deficiencies and extent of condition.

• Review of the Maintenance Rule 50.65(a)(3) 'living' assessment process

• Unit 1, 'B1G' load sequencer degraded cabinet door latch

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the four maintenance activities listed below to verify that the licensee assessed and managed plant risk as required by 10 CFR 50.65(a)(4) and licensee procedures. The inspectors assessed the adequacy of the licensee's risk assessments and implementation of risk management actions. The inspectors also verified that the licensee was identifying and resolving problems with assessing and managing maintenance-related risk using the corrective action program. Additionally, for maintenance resulting from unforeseen situations, the inspectors assessed the effectiveness of the licensee's planning and control of emergent work activities.

• Units 1 & 2, April 3, 2017, severe weather impacts; 230kV Webb Line outage; and 2A RHR pump equipment outage

• Unit 1 , April 10, 2017, 1A RHR pump equipment outage, 230 kV Webb Line outage

• Unit 2, May 2, 2017, Shared 1C diesel generator outage

• Unit 1, May 17, 2017, 1B RHR pump equipment outage, 230kV Sinai Cemetery Line outage

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

Operability Determinations and Functionality Assessments Review: The inspectors selected the five operability determinations or functionality evaluations listed below for review based on the risk-significance of the associated components and systems. The inspectors reviewed the technical adequacy of the determinations to ensure that technical specification operability was properly justified and the components or systems remained capable of performing their design functions. To verify whether components or systems were operable, the inspectors compared the operability and design criteria in the appropriate sections of the technical specification and updated final safety analysis report to the licensee's evaluations. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with operability evaluations.

• CR 10327263, unexpected voltage indications on the 2B diesel during start

• CR 10360706, 1C diesel generator cross drive assembly measurements

• CR 10364598, Penetration room filtration (PRF) boundary door left open

• CR 10364979, Unit 2 containment pressure channel 3, PT-952 drifting low

• CR 10359183, Unit 2 East cable tunnel ground water in-leakage

b. Findings

Introduction:

The NRC identified a Green non-cited violation (NCV) of Technical Specification (TS) 5.4.1.a, "Procedures," when inspectors found the 1A containment spray (CS) pump room door (door 106) open on May 12, 2017, without the required dedicated individual to close the door. As a result, the penetration room filtration (PRF)system boundary was inoperable which rendered both trains of the PRF system inoperable. Failure to follow section 19.0 of licensee procedure FNP-0-SOP-0.0, Version 163, was a performance deficiency.

Description:

While conducting maintenance to repair the 1A containment spray pump on May 12, 2017, the pump room door (door 106) was left open to provide additional ventilation for workers in the area. The door was posted with a sign that required permission from Operations shift supervisors to leave the door open because the door was a penetration room filtration system boundary door. The inspectors noted that the licensee considers the PRF boundary inoperable when door 106 is open. Technical Specifications limiting condition of operation (LCO) 3.7.12, "PRF System," required two trains of PRF to be operable in Modes 1 through 4. Condition B required restoration of the PRF boundary to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This door was opened several times during the night shift for a few minutes each time and approximately four hours during day shift on May 12. Licensee procedure FNP-0-SOP-0.0, "General Instructions to Operations Personnel," Version 163, Section 19.0, required a dedicated individual in the area with continuous communication with the control room if a door is left open. This individual would be required to close the door when directed by the control room. The inspectors observed the door open without the dedicated individual required by the procedure and informed the Unit 1 shift supervisor. The door was closed within approximately five minutes of notifying the shift. According to section 6.2.3.3.2 of the updated final safety analysis report (UFSAR), the PRF system ensures that offsite radiation exposures resulting from post loss of coolant accident (LOCA) emergency core cooling systems (ECCS) recirculation leakage are within the guidelines of 10 CFR 100.

Analysis:

The failure to implement Section 19.0 of licensee procedure FNP-0-SOP-0.0, Version 163, was a performance deficiency. Specifically, a dedicated individual with continuous communications with the control room was not established on May 12, 2017, when door 106 was left open to support maintenance on the 1A CS pump. The performance deficiency was more than minor because it was associated with the structure, system, component and barrier performance attribute of the barrier integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, when door 106 was open, the PRF system boundary was inoperable which caused both PRF trains to be inoperable. Without the dedicated individual to close the door as directed, the ability of the PRF system to perform its safety function was compromised. The significance of this finding was evaluated using IMC 0609, Appendix A, "The Significance Determination Process (SDP)for Findings At-Power," dated June 19, 2012. This finding was of very low safety significance (Green) because the finding only represented a degradation of the radiological barrier function provided for the auxiliary building through the PRF system. The inspectors determined the finding had a cross-cutting aspect of Teamwork in the Human Performance area because maintenance did not effectively communicate and coordinate their activities with operations to ensure the requirements were met when door 106 was left open [H.4].

Enforcement:

Technical Specification 5.4.1.a, "Procedures," required, in part, that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Regulatory Guide (RG) 1.33, Revision 2, Appendix A. Section 1.c of RG 1.33, Appendix A, recommended administrative procedures for equipment control. Licensee procedure Licensee procedure FNP-0-SOP-0.0, "General Instructions to Operations Personnel," Version 163, Section 19.0, required a dedicated individual in the area with continuous communication with the control room if a door is left open. The dedicated individual would be necessary to close the door as directed by the control room. This procedure is considered safety-related.

Contrary to the above, on May 12, 2017, door 106 was left open to support maintenance on the 1A CS pump without the dedicated individual in the area. This event was captured in the licensee's corrective action program with condition report (CR) 10364598. The licensee restored compliance with the procedure by closing the door within approximately five minutes of being notified of the issue by the inspectors.

Because this finding is of very low safety significance and has been entered into the corrective action program, this violation was treated as an NCV, consistent with the Enforcement Policy. NCV 05000348/2017002-02 "Failure to Follow Procedure Resulted in Inoperable PRF System Boundary."

1R18 Plant Modifications

a. Inspection Scope

For the following plant modification listed below, the inspectors;

• Verified that the modification did not affect the safety functions of important safety systems.

• Confirmed the modification did not degrade the design bases, licensing bases, and performance capability of risk significant structures, systems and components.

• Verified modification performed during plant configurations involving increased risk did not place the plant in an unsafe condition.

• Evaluated whether system operability and availability, configuration control, post-installation test activities, and changes to documents, such as drawings, procedures, and operator training materials, complied with licensee standards and NRC requirements.

• Reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with modification.

o Design Change Package (DCP) SNC761674, Unit 1 Auxiliary Building Seismic Gap Modification

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors either observed post-maintenance testing or reviewed the test results for the six maintenance activities listed below to verify the work performed was completed correctly and the test activities were adequate to verify system operability and functional capability.

• Work Order (WO) SNC775429, 2A RHR motor lugging inspection

• WO SNC859060, 2B DG jacket water keep warm pump

• WO SNC772675, 1A containment spray pump repair

• WO SNC583447, 2B RHR pump lockout relay MG-6 inspection and test

• WO SNC865256, Replace the 1C diesel governor

• WO SNC795521, Seismic gap repairs The inspectors evaluated these activities for the following:

• Acceptance criteria were clear and demonstrated operational readiness.

• Effects of testing on the plant were adequately addressed.

• Test instrumentation was appropriate.

• Tests were performed in accordance with approved procedures.

• Equipment was returned to its operational status following testing.

• Test documentation was properly evaluated. Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with post-maintenance testing.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the four surveillance tests listed below. The surveillance test was either observed directly or test results were reviewed to verify testing activities and results provide objective evidence that the affected equipment remain capable of performing their intended safety functions and maintain their operational readiness consistent with the facility's current licensing basis. The inspectors evaluated the test activities to assess for:

• preconditioning of equipment,

• appropriate acceptance criteria,

• calibration and appropriateness of measuring and test equipment,

• procedure adherence, and

• equipment alignment following completion of the surveillance.

Additionally, the inspectors reviewed a sample of significant surveillance testing problems documented in the licensee's corrective action program to verify the licensee was identifying and correcting any testing problems associated with surveillance testing. Routine Surveillance Tests

• FNP-2-STP-11.1, 2A RHR Pump Quarterly Inservice Test, Ver. 45.0

• FNP-0-STP-80.10, Diesel Generator 2C 1000KW Load Rejection Test, Ver. 28.1

• FNP-2-STP-80.1, DG 2B Operability Test, Ver. 57.1 In-Service Tests (IST)

• FNP-1-STP-23.2, 1C Component Cooling Water Pump Quarterly Inservice Test, Ver. 44

b. Findings

Introduction:

The NRC identified an apparent violation (AV) of Technical Specification (TS) 5.4.1.a, "Procedures," for the licensee's failure to implement corrective maintenance work order instructions to identify and replace a degraded jacket water fitting on the 2B emergency diesel generator (EDG) jacket water keep warm system piping. As a result, a leak occurred on the 2B EDG jacket water piping system during surveillance testing which rendered the EDG inoperable. The inspectors determined that the failure to follow work order instructions to replace degraded jacket water system piping during corrective maintenance on the 2B DG on March 3, 2017, was a performance deficiency.

Description:

During a monthly surveillance test of the 2B EDG on April 21, 2017, the inspectors observed a leak on the 2B EDG jacket water keep warm pump discharge piping. Following the leak discovery, the EDG was shut down (test aborted) and Condition report (CR) 10356955 was initiated to document the condition. The threaded pipe (nipple) removed from the jacket water keep warm pump discharge nozzle was the apparent cause of the leak, since it had thread damage. The inspectors observed the physical condition of the damaged pipe nipple and then reviewed previous corrective maintenance records and found WO SNC837488 had been implemented on March 3, 2017, to repair a previous leak at the same piping location. The work order instructions required the maintenance staff to disconnect piping where the leak(s) are identified, inspect and clean piping threads, and replace piping as necessary. The inspectors noted that the work order instruction to replace piping had not been performed and was marked "N/A" in the work order. Following identification of the leak, the licensee implemented WO SNC859060 and repaired the 2B EDG on April 22, 2017, and satisfactory post maintenance testing was completed.

The jacket water system removes heat generated in the engine cylinders and turbocharger housings and maintains jacket coolant out of the engine in the 145°F to 165°F range. The jacket water system is a closed cooling/heating system including a heat exchanger, an electric standby jacket water heater, pumps, and an expansion tank (manually filled with demineralized water or service water as a backup). Without jacket water cooling, potentially catastrophic engine failure can result. Technical Specification 5.4.1 required written procedures be established, implemented, and maintained covering the applicable procedures recommended in RG 1.33, Rev. 2, Appendix A, February 1978. Section 9.a of RG 1.33 required in part that maintenance that can affect the performance of safety-related (SR) equipment should be properly pre-planned and performed in accordance with documented instructions appropriate to the circumstances. The inspectors concluded that the licensee's failure to follow work order instructions resulted in inadequate corrective maintenance on March 3, 2017, on the 2B EDG jacket water keep warm pump discharge piping which led to an uncontrolled jacket water leak during the monthly surveillance test of the 2B EDG on April 21, 2017.

Analysis:

The inspectors determined that the failure to follow work order instructions to replace degraded jacket water system piping during corrective maintenance on the 2B EDG on March 3, 2017, was a performance deficiency. The finding was more than minor because it was associated with the equipment reliability attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The significance of this finding was evaluated using IMC 0609, Appendix A, "The Significance Determination Process (SDP) for Findings At-Power," dated June 19, 2012. Initial screening by the resident inspectors using the Sapphire Farley 1 & 2 SPAR Model resulted in a potentially greater-than-green significance. Therefore, a detailed risk analysis will be performed by a regional senior reactor analyst (SRA). The finding had a cross-cutting aspect of Conservative Bias in the Human Performance area, because the decision to leave the diesel in a degraded condition following maintenance was neither conservative nor prudent when additional action could have been taken to adequately repair or evaluate the piping connection

[H.14].

Enforcement:

Technical Specification 5.4.1 required, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in RG 1.33, Revision 2, Appendix A, February 1978. Section 9.a of RG 1.33 required, in part, that maintenance that can affect the performance of safety-related (SR) equipment should be properly pre-planned and performed in accordance with documented instructions appropriate to the circumstances. Work Order (WO) SNC837488 was implemented on March 3, 2017, to repair a leak at the 2B EDG jacket water keep warm pump discharge piping. The WO instructions required the maintenance staff to disconnect piping where the leak(s) are identified, inspect and clean piping threads, and replace piping as necessary. Contrary to the above, on March 3, 2017, the licensee failed to conduct maintenance affecting SR equipment in accordance with documented instructions appropriate to the circumstances. Specifically, the licensee did not implement work order instructions to identify and replace a damaged threaded pipe. As a result, the 2B EDG was rendered inoperable until corrected on April 22, 2017. The licensee initiated CR 10356955 to document the condition. Pending final determination of the safety significance, this finding is identified as AV 05000364/2017002-03, "Failure to perform adequate corrective maintenance on the 2B EDG."

Cornerstone:

Emergency Preparedness 1EP2 Alert and Notification System Evaluation

a. Inspection Scope

The inspectors evaluated the adequacy of the licensee's methods for testing and maintaining 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 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, were also used as a reference.

The inspectors reviewed various documents which are listed in the Attachment and interviewed personnel responsible for system performance. 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 Response Organization Staffing and Augmentation System

a. Inspection Scope

The inspectors reviewed the licensee's 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 system tests performed since the last inspection was 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 inspectors 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

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

Since the last NRC inspection of this program area, two changes were made to the Radiological Emergency Plan, three changes were made to the emergency action levels, and several changes were made to the implementing procedures. The licensee determined that, in accordance with 10 CFR 50.54(q), the Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The inspectors reviewed these changes to evaluate for potential reductions in the 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 standards of 10 CFR 50.47(b), and its related requirements in 10 CFR 50, Appendix E were used as reference criteria. The inspectors reviewed various documents that are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the emergency action level and emergency plan changes on an annual basis.

b. Findings

No findings were identified. 1EP5 Maintenance of Emergency Preparedness

a. Inspection Scope

The inspectors reviewed the corrective actions identified through the Emergency Preparedness program to determine the significance of the issues, the completeness and effectiveness of corrective actions, and to determine if issues were recurring. The licensee's post-event after action reports, self-assessments, and audits were reviewed to assess the licensee's ability to be self-critical, thus avoiding complacency and degradation of their emergency preparedness program. Inspectors reviewed the licensee's 10 CFR 50.54(q) change process, personnel training, and selected screenings and evaluations to assess adequacy. The inspectors toured facilities and reviewed equipment and facility maintenance records to assess licensee's adequacy in maintaining them. The inspectors evaluated the capabilities of selected radiation monitoring instrumentation to adequately support Emergency Action Level (EAL) declarations.

The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 05, and Maintenance of Emergency Preparedness. The applicable planning standards, related 10 CFR 50, Appendix E requirements, and 10 CFR 50.54(q) and (t)were used as reference criteria. The inspectors reviewed various documents which are listed in the Attachment. This inspection activity satisfied one inspection sample for the maintenance of emergency preparedness on a biennial basis.

b. Findings

Introduction:

The inspectors identified a self-revealing Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) Part 50.54(q)(2), Part 50.47(b)(4), and Appendix E,Section IV.C.2, for the failure to declare a Notification of Unusual Event (NOUE), during an actual event. Specifically, on November 1, 2016, Farley Unit 1 experienced conditions that met Emergency Action Level (EAL) HU3, Release of Toxic, Asphyxiant, or Flammable Gases Deemed Detrimental to Normal Operation of the Plant.

The failure to declare a NOUE during an actual event was considered a performance deficiency.

Description:

At 5:43 p.m. on November 1, 2016, the licensee declared an Alert emergency classification based on 'measured' ammonia levels inside the Auxiliary Building (AB) 100' elevation, which is considered a vital area that is encompassed by the owner controlled area. The Alert classification was based on initiating condition EAL HA3 which states, "Release of toxic, asphyxiant, or flammable gases within or contiguous to a vital area which jeopardizes operation of systems required to maintain safe operations or establish or maintain safe shutdown." However, before the Alert declaration was made conditions were met for a NOUE classification. The initiating condition for NOUE EAL HU3, "Release of toxic, asphyxiant, or flammable gases deemed detrimental to normal operation of the plant," was met when ammonia was detected in a vital area. The "strong" smell of ammonia was reported to the control room by a non-licensed operator at approximately 3:00 p.m., breathing hazard postings were hung, a fan to ventilate the area was set up, and a fire watch was not permitted to enter the area. It was at this time that normal plant operations were being affected and that the licensee had enough information to make the NOUE declaration.

Corrective actions included entering the issue into the licensee's corrective action program (CAP) as condition report (CR) 10293519, issuing a Standing Order that provides threshold values for measuring ammonia and other chemicals, and formally evaluating the decision-making process used during the event. There were at least 29 other CRs and 16 Technical Evaluation CAP items as a result of this event.

Analysis:

The failure to declare a NOUE during an actual event was considered a performance deficiency. This finding was more than minor because it was associated with the Emergency Preparedness cornerstone attribute of Emergency Response Organization Performance (actual event response), and adversely affected the cornerstone objective of ensuring that a licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, on November 1, 2016, Farley Unit 1 experienced conditions that met EAL HU3 for declaring a NOUE when toxic gas (ammonia) was detected in a vital area, which is also part of the owner controlled area. The performance deficiency is associated with the Emergency Classification Planning Standard 10 CFR 50.47(b)(4) and Appendix E Section IV.C.2, and is considered a Risk Significant Planning Standard (RSPS). The failure to declare a NOUE when directed by the EAL Matrix is considered a lost or degraded RSPS in accordance with Section 4 of Inspection Manual Chapter (IMC) 0609, Appendix B. Section 4.3.e of IMC 0609, Appendix B, provides the significance determination for a "Failure to Implement," and the performance deficiency was determined to be of a low safety significance (Green). The finding was also determined to be associated with a cross-cutting aspect in the Training component of the Human Performance area because the organization did not provide adequate training to the various ERO members involved in this event to ensure knowledge transfer to maintain a knowledgeable, technically competent workforce, and instill nuclear safety values [H.9].

Enforcement:

Title 10 CFR Part 50.54(q)(2) requires that a holder of a nuclear power reactor operating license under this part, follow and maintain the effectiveness of an emergency plan that meets the requirements of 10 CFR 50.47(b). Title 10 CFR Part 50.47(b)(4) requires a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures. Title 10 CFR Part 50, Appendix E, Section IV.C.2, requires licensees to establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after availability of indications to plant operators that an emergency action has been exceeded. Contrary to the above, on November 1, 2016, the licensee failed to maintain the capability to assess and declare a NOUE classification by not recognizing that the detection of ammonia in the auxiliary building, which is encompassed by the owner controlled area, met the conditions for declaring a NOUE. Corrective actions included entering the issue into the licensee's CAP as condition report (CR) 10293519, issuing a Standing Order that provides threshold values for measuring ammonia and other chemicals, and formally evaluating the decision-making process used during the event. The failure to follow and maintain the effectiveness of an emergency plan to meet the requirements of 10 CFR Part 50.47(b)(4) and Part 50 Appendix E is identified as NCV 05000348/2017002-01, "Failure to Declare an Unusual Event During an Actual Event."

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors observed the emergency preparedness drill conducted on May 24, 2017. The inspectors observed licensee activities in the simulator and/or technical support center to evaluate implementation of the emergency plan, including event classification, notification, dose assessment, and protective action recommendations. The inspectors evaluated the licensee's performance against criteria established in the licensee's procedures. Additionally, the inspectors attended the post-exercise critique to assess the licensee's effectiveness in identifying emergency preparedness weaknesses and verified the identified weaknesses were entered in the corrective action program.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

a. Inspection Scope

The inspectors reviewed a sample of the performance indicator (PI) data, submitted by the licensee, for the Unit 1 and Unit 2 PIs listed below. The inspectors reviewed plant records compiled between April 2016 and March 2017, to verify the accuracy and completeness of the data reported for the station. The inspectors verified that the PI data complied with guidance contained in Nuclear Energy Institute 99-02, "Regulatory Assessment Performance Indicator Guideline," and licensee procedures. The inspectors verified the accuracy of reported data that were used to calculate the value of each PI. In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with PI data.

Cornerstone:

Mitigating Systems

• residual heat removal system (both units)

• cooling water system (both units) Emergency Preparedness Cornerstone

• Drill/Exercise Performance (DEP)

• Emergency Response Organization (ERO) Readiness

• Alert and Notification System (ANS) Reliability For the specified review period, the inspectors examined data reported to the NRC, procedural guidance for reporting PI information, and records used by the licensee to identify potential PI occurrences. The inspectors verified the accuracy of the PI for ERO drill and exercise performance through review of a sample of drill and event records.

The inspectors reviewed selected training records to verify the accuracy of the PI for ERO drill participation for personnel assigned to key positions in the ERO. The inspectors verified the accuracy of the PI for alert and notification system reliability through review of a sample of the licensee's records of periodic system tests. The inspectors also interviewed the licensee personnel who were responsible for collecting and evaluating the PI data. Licensee procedures, records, and other documents reviewed within this inspection area are listed in the Attachment. This inspection satisfied three inspection samples for PI verification on an annual basis.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

The inspectors screened items entered into the licensee's corrective action program in order to identify repetitive equipment failures or specific human performance issues for follow-up. The inspectors reviewed condition reports, attended screening meetings, or accessed the licensee's computerized corrective action database.

.2 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of issues entered in the licensee's corrective action program (CAP) and reviewed associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors focused their review on control of transient combustibles in risk significant areas of the plant, but also considered the results of inspector daily condition report screenings, licensee trending efforts, and licensee human performance results. The review nominally considered the 6-month period beginning in January 2017 through June 2017, although some examples extended beyond those dates when the scope of the trend warranted. The inspectors compared their results with the licensee's analysis of trends. Additionally, the inspectors reviewed the adequacy of corrective actions associated with a sample of the issues identified in the licensee's trend reports. The inspectors also reviewed corrective action documents that were processed by the licensee to identify potential adverse trends in the condition of structures, systems, and/or components as evidenced by acceptance of long-standing non-conforming or degraded conditions.

b. Findings and Observations

No findings were identified. The inspectors performed a search of the CAP database and found 25 examples of condition reports initiated since the beginning of 2017 associated with the control of transient combustibles. The licensee identified an adverse trend with compliance with the transient combustible control program and initiated a trend condition report (CR) 10323400 on January 27, 2017, citing five CRs as examples and noted that the trend had continued over the previous 60 days. Since that time there were an additional nineteen CRs initiated for issues associated with transient combustible control. The licensee initiated Technical Evaluation (TE) 978353 in an effort to resolve the negative trend, but it is not apparent the licensee's corrective actions were effective at correcting long term behaviors, since the negative trend continues. The inspectors continue to monitor this issue.

.3 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors conducted a detailed review of condition report (CR) 10315948 and corrective action report (CAR) 268251. This report was a root cause determination to evaluate the decline in equipment performance over the past 18 months.

The inspectors evaluated the following attributes of the licensee's actions:

• complete and accurate identification of the problem in a timely manner

• evaluation and disposition of operability and reportability issues

• consideration of extent of condition, generic implications, common cause, and previous occurrences

• classification and prioritization of the problem

• identification of root and contributing causes of the problem

• identification of any additional condition reports

• completion of corrective actions in a timely manner

b. Findings

No findings were identified.

4OA3 Follow-up of Events

.1 (Closed) LER 05000348/2016-007-00 and 2016-007-01 Plant Shutdown Required by Technical Specifications due to Inoperable Steam Flow Transmitters

a. Inspection Scope

The inspectors reviewed these LERs for potential performance deficiencies and/or violations of regulatory requirements. Additionally, discussions were held with operations, engineering, and licensing staff members to understand the details surrounding this issue. This condition was documented in the licensee's corrective action program as CR 10299704. During the licensee's engineering review of cycle full power scaling values for steam flow normalization at the beginning of a new fuel cycle for Unit 1 while in Mode 1 at 99 percent reactor power, three steam flow channel values were found to be non-conservative and outside of +/- 2.5% delta pressure scan. This non-conservatism would allow steam flow to exceed the Technical Specification trip set-point before a steam line isolation would occur. Unit 1 initiated a plant shutdown on November 17, 2016 at 1859 in accordance with Limiting Condition for Operation (LCO)3.0.3 for having no operable steam flow channels for the C Steam Generator (SG). The two steam flow channels did not meet acceptance criteria for Technical Specification (TS) 3.3.2. At 1951 the licensee made a 4-hour non-emergency report to the NRC and on November 18, 2016 at 0041 Unit 1 plant shutdown was completed and the plant entered Mode 3, as required by LCO 3.0.3. The inspectors reviewed the licensee's condition report 10299704 and associated documents, and met with licensee engineering and operations personnel. The steam flow transmitters were restored to operable status by calculating new scaling data and rescaling the channels. LERs 05000348/2016-007-00 and 2016-007-01 are closed.

c. Findings

No findings were identified.

.2 (Closed) LER 05000348, 364/2016-009-00, Tornado Missile Vulnerabilities Result in Condition Prohibited by Technical Specifications

a. Inspection Scope

On December 7, 2016, licensee staff determined that the Unit 1 and 2 service water structure intake and exhaust ventilation hoods were not adequately protected from tornado generated missiles. On January 26, 2017, it was also identified that the emergency diesel generator fuel oil storage tank vents were not adequately protected from tornado generated missiles. Upon discovery, the on-shift Operations staff declared the service water pumps and emergency diesel generators inoperable and implemented Enforcement Guidance Memorandum (EGM) 15-002, "Enforcement Discretion for Tornado-Generated Missile Protection Noncompliance." The licensee made a non-emergency report in accordance with 10 CFR 50.72(b)(3)(ii)(B) and 10 CFR 50.72(b)(3)(v)(D) via EN 52414. These items were entered into the licensee's CAP and discussed with the resident inspectors. The inspectors reviewed this LER, EGM 15-002 and verified the licensee implemented adequate compensatory measures in accordance with interim staff guidance DSS-ISG-2016-01, "Clarification of Licensee Actions in Receipt of Enforcement Discretion per Enforcement Guidance Memorandum EGM 15-002." Final corrective actions to resolve these issues are pending.

b. Findings

On December 7, 2016, licensee determined that the Unit 1 and 2 service water structure intake and exhaust ventilation hoods were not adequately protected from tornado generated missiles. On January 26, 2017, the licensee also identified that the emergency diesel generator fuel oil storage tank vents were not adequately protected from tornado generated missiles. The licensee declared the service water pumps and emergency diesel generators inoperable, implemented compensatory measures and declared the affected equipment operable but nonconforming. These issues were entered into the licensee's corrective action program and discussed with the resident inspectors. The inspectors reviewed the circumstances associated with the event report and verified the licensee implemented compensatory measures consistent with interim staff guidance DSS-ISG-2016-01, "Clarification of Licensee Actions in Receipt of Enforcement Discretion per Enforcement Guidance Memorandum EGM 15-002," (ADAMS ML15348A202). Because this violation was identified during the discretion period covered by Enforcement Guidance Memorandum 15-002, Revision 1, "Enforcement Discretion for Tornado Missile Protection non-compliance," (ADAMS ML16355A286) and because the licensee had implemented compensatory measures, the NRC is exercising discretion (EA-17-131) and not issuing enforcement action.

The enforcement discretion was applied to the required shutdown actions of the following Technical Specification (TS) LCOs for both units: TS 3.7.8, "Service Water System (SWS)" TS 3.8.1, "AC Sources - Operating" Final corrective actions to resolve these issues will be addressed by the licensee's corrective action program. The licensee has entered this issue into the corrective action program as condition reports 10306023 and 10322897. This LER is closed.

.3 (Closed) LER 05000348/2016-008-00, Manual Rector Trip Due to Generator Voltage Swings

a. Inspection Scope

On November 26, 2016, while Unit 1 was operating at 100 percent reactor power, the main generator experienced voltage and load swings. According to the licensee's troubleshooting efforts and causal evaluation, these swings were caused by an intermittent failure of the voltage isolation transducer which is part of the main generator voltage regulator circuit. Unit 1 was manually tripped approximately 30 minutes after the voltage and load swings were observed by the main control room staff. The licensee made a non-emergency report in accordance with 10 CFR 50.72(b)(2)(iv)(B)and 50.72(b)(3)(iv)(A) via EN 52395. The inspectors reviewed the LER and discussed the event with members of the plant staff. Additional documents reviewed are included in the Attachment.

b. Findings

No findings were identified.

.4 (Closed) Licensee Event Report (LER) 05000348/2016-005-00, Toxic Gas Event

a. Inspection Scope

The inspectors reviewed LER 05000348/2016-005-00 dated December 28, 2016. This LER discusses an Alert that was declared on November 1, 2016, based on toxic gas (ammonia) levels within or contiguous to a vital area reaching an emergency action level threshold. The inspectors reviewed the LER associated with this event and determined that the report adequately documented the summary of the event including the cause of the event and potential safety consequences. The licensee performed two root cause analyses, one to address the equipment and process part of the event, and another to address the lack of timeliness in evaluating and declaring the appropriate event classification. Most of the corrective actions are complete, except those that may stem from the non-cited violation associated with this event.

b. Findings

The finding associated with this event is contained in Section 1EP5 of this report.

4OA5 Other Activities

.1 Operation of an Independent Spent Fuel Storage Installation (ISFSI) (60855.1)

a. Inspection Scope

The inspectors performed a walkdown of the onsite ISFSI on June 27, 2017, and monitored the activities associated with the Unit 1 dry fuel storage campaign completed on June 23, 2017. The inspectors reviewed changes made to the ISFSI programs and procedures, including associated 10 CFR 72.48, "Changes, Tests, and Experiments,"

screens and evaluations to verify that changes made were consistent with the license or certificate of compliance. The inspectors observed the loading activities to verify that the licensee recorded and maintained the location of each fuel assembly placed in the ISFSI.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit On July 27, 2016, the resident inspectors presented the inspection results to

Mr. John Horn and other members of the licensee's staff. The inspectors confirmed that proprietary information provided or examined during the inspection period was properly controlled. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

K. Baity, Site Design Manager

S. Briggs, Plant Manager

J. Carroll, Operations Support Manager

B. Freeman, Engineering Supervisor

S. Harris, Shift Operations Manager

J. Horn, Operations Director

N. Koteel, Operations

D. Madison, Site Vice President

J. Short, Maintenance Director

D. Simmons, EP Supervisor

J. Summy, Engineering Director

G. Surber, Licensing Supervisor

R. Wells, Site Projects Manager

E. Williford, Regulatory Affairs Manager - Interim

LIST OF REPORT ITEMS

Opened and Closed NCV

05000348/2017002-01 Failure to Declare an Unusual Event During an Actual Event (1EP5) NCV

05000348/2017002-02 Failure to Follow Procedure Resulted in Inoperable PRF System Boundary (1R15)

Opened

AV

05000364/2017002-03 Failure to perform adequate corrective maintenance on the 2B EDG (1R22)

Closed LER

05000348/2016-007-00 and 2016-007-01 Plant Shutdown Required by Technical Specifications due to Inoperable Steam Flow Transmitters (4OA3.1) LER

05000348,

05000364 /2016-009-00 Tornado Missile Vulnerabilities Result in Condition Prohibited by Technical Specifications (4OA3.2)

LER

05000348/2016-008-00 Manual Rector Trip Due to Generator Voltage Swings (4OA3.3) LER

05000348/2016-005-00 Toxic Gas Event (4OA3.4)

Section 1R01: Adverse Weather Protection Procedures:

NMP-AD-014, Requirements for Compliance with NERC Standards, Ver. 6.1

NMP-AD-014-GL01, Guidelines for Compliance with NERC Standards, Ver. 6.0

FNP-1-UOP-3.1, Power Operation, Ver. 127

FNP-1-SOP-36.2, 4160V AC Electrical Distribution System, Ver. 30

FNP-2-SOP-36.2, 4160V AC Electrical Distribution System, Ver. 33.2

FNP-1-STP-27.1, AC Source Verification, Ver. 39.0

FNP-1-ARP-1.12, Annunciator Response Procedure, Main Control Board Panel M, Ver. 65.1

FNP-1-ARP-1.13, Annunciator Response Procedure, Main Control Board Panel N, Ver. 22.1

FNP-0-ARP-2.2, Annunciator Response Procedure, Emergency Power Board Panel W,

Ver. 35.1

FNP-1-AOP-5.2, Degraded Grid, Ver. 16.1

NMP-OS-020, Station Response to Southern Company System Alert Conditions, Ver. 1.2

FNP-0-AOP-21, Rev. 45

NMP-OS-017, Ver. 1.1

Drawings: D-173000, Units 1 & 2 Low Voltage Switchyard Layout, Ver. 9

D-177001, Unit 1, Single Line Electrical Auxiliary System (Emergency 4160 & 600V), Ver. 23.0

D-207001, Unit 2, Single Line Electrical Auxiliary System (Emergency 4160 & 600V), Ver. 21.0

Documents: SNC

NUC-001,

NUC-001 Nuclear Plant Interface Coordination for Southern Nuclear Operating Company, Ver. 2.0 High Voltage Switchyard Morning Report, June 14, 2017

Condition Reports:

10350510,

10361778,

10361790,

10368976, 10370875

Section 1R04: Equipment Alignment Drawings:

D-175038, Unit 1 P&ID - Safety Injection System, Sheet 1, Ver. 37.0 D-175038, Unit 1 P&ID - Safety Injection System, Sheet 2, Ver. 20.0

D-175041, Unit 1 P&ID - Residual Heat Removal System, Sheet 1, Ver. 18.0

D-175038, Unit 1 P&ID - Safety Injection System (cont. spray), Sheet 3, Ver. 27 D-175012, HVAC & Filter P&ID, Control Room and Computer Room, Sheet 1, Ver. 40 D-205012, HVAC & Filter P&ID, Control Room and Computer Room, Sheet 1, Ver. 41 D-175046, HVAC & Filt. Process Flow Diag. Control Rm. & Computer Rm., Sheet 1, Ver. 19.0

Procedures:

FNP-1-SOP-7.0A, Residual Heat Removal System, Ver. 10

FNP-0-SOP-38.0B, 1B Diesel Generator, Ver. 14

FNP-0-SOP-38.0-1B, Ver.15

FNP-0-SOP-38.0, Ver. 126

FNP-1-SOP-9.0A, Ver. 9

FNP-0-SOP-56.0, Control Room HVAC System, Ver. 58.0

FNP-0-SOP-56.0A, Control Room HVAC System, Ver. 17.0

Condition Reports: 10359420

Section 1R05: Fire Protection Annual/Quarterly Drawings: D356847, Unit No. 2 - Fire Barriers and Fire Boundaries - U2 Auxiliary Building and Containment El. 121', 127' & 129', Ver. 1.0

Documents: A-181805, NFPA 805 Fire Protection Program Design Basis Document, Ver. 1.0

WO SNC574136,

FNP-2-FSP-63.5, Visual Inspection of Penetration Fire Barriers (Auxiliary Building: 121' El. Mezzanine, Cable Chase, Control System Cab. Room), Ver. 7.0 WO SNC592244,

FNP-2-FSP-63.4, Visual Inspection of Penetration Fire Barriers (Auxiliary Building: 121' El. Switchgear Room, Duct Chase, CRDM Room), Ver. 7.0 WO SNC601721,

FNP-2-FSP-63.2, Visual Inspection of Penetration Fire Barriers (Auxiliary Building: 121' El. Walkway, Computer Room, Corridor), Ver. 5.0 WO SNC633336,

FNP-2-FSP-63.03, Visual Inspection of Penetration Fire Barriers (Auxiliary Building 121' El. Battery Charging Room Area, Cable Chase), Ver. 8.0 WO SNC717908,

FNP-2-FSP-39.1, Portable CO2 Fire Extinguishers - Annual Conductivity Test, Ver. 4.0

WO-SNC724663,

FNP-2-FSP-65.2, Fire Doors Functional Inspection Auxiliary Building, Ver. 14.0 WO SNC807233,

FNP-2-FSP-9.0, Portable Extinguishers - Monthly, Ver. 26.0 WO SNC474100,

FNP-2-FSP-307.0, Smoke Detectors - Biennial Operability and Adjustment, Ver. 20.0 WO SNC668553,

FNP-2-FSP-405.0, Preaction Sprinkler System (Annual), Ver. 18.0

Procedures:

FNP-0-AOP-29, Rev. 47

FNP-0-SOP-0.4, Ver. 100

FNP-2-FPP-1.0, Unit 2 Auxiliary Building Pre-Fire Plan, Ver. 1.0

Condition Reports:

10351965,

10380956, 10381664

Section 1R11: Licensed Operator Requalification Program Documents: Farley Operations Training Simulator Exam Scenario #28, June 1, 2017

Procedures:

NMP-TR-416, Licensed Operator Continuing Training Program Administration, Ver. 7

NMP-OS-007, Conduct of Operations, Ver. 11

NMP-EP-110-GL01, FNP EALs - ICs, Threshold Values and Basis, Ver. 9.0

Section 1R12: Maintenance Effectiveness Documents:

NUMARC 93-01, Rev. 4A

MR functional scoping document for function E11-F03

MR Scorecard - April 2017

EVAL-F-W41-03467, MR (a)(1) plan

EVAL-F-N11-03387, MR (a)(1) plan

EVAL-F-N43-03747, MR (a)(1) plan

EVAL-F-N11-03227, MR (a)(1) plan

CAR 268756

Technical Evaluations:

970904,

980036,

980084

Condition Reports:

10284045,

10342244,

10330646,

10343524,

10343528

Procedures:

NMP-ES-027, Maintenance Rule Program, Ver. 6

NMP-ES-027-001, Maintenance Rule Implementation, Ver. 8

Section 1R13: Maintenance Risk Assessments and Emergent Work Evaluation Procedures:

NMP-GM-031, On-Line Configuration Risk Management Program, Ver. 3.0

NMP-GM-031-001, Online Maintenance Rule (a)(4) Risk Calculations, Ver. 3.0

NMP-OS-010, Protected Train/Division and Protected Equipment Program, Ver. 7.2

NMP-OS-010-001, Farley Protected Equipment Logs, Ver. 14.0

Condition Reports:

Documents: Unit 1 Operator's Risk Report (various scenarios in EOOS) - April 3, 2017 Unit 1 Operator's Risk Report - April 10, 2017 Unit 2 Operator's Risk Report - May 2, 2017 Unit 1 Operator's Risk Report - May 17, 2017

Section 1R15: Operability Determinations and Functionality Assessments Drawings:

D-202779, Ver. 16

D-202778, Ver. 24

D-202776, Ver. 8 D-175013, Sheet 1, Ver. 10 D-175022, Sheet 1, Ver. 30

Documents: Work Orders

SNC 859228,

859258,

867854 U184804, Diesel Generator Operations and Maintenance Manual, Ver. 31

Prompt Determination of Operability (PDO): 0-17-02, Ver. 1 Administrative Tracking Item (ATI) #1551

CAR 266406, Plant Hatch Root Cause Report, Ver. 2

Procedures:

FNP-2-STP-80.1, Ver. 57.1

FNP-0-SOP-0.0, Ver. 163

NMP-AD-012, 13.1

Condition Reports:

10363323, 10365421,

Section 1R18: Plant Modifications Procedures:

NMP-ES-084-001-F04, Design Change/Modification Impact Review Form, Ver. 1.1

NMP-AD-008-F01, Applicability Determination, Ver. 11.1

Procedures:

NMP-GM-002, Corrective Action Program, Ver. 14.2

FNP-1-STP-20.2, Penetration Room Filtration System Train A and B Monthly Operability Test, Ver. 25.0

Condition Reports:

CR 10372422,

10372987

Documents: SNC761674

WO SNC795521

EN 52785

==Section 1R19: Post Maintenance Testing Condition Reports:

10350174,

10350197,

10350730,

10351012,

10353514,

10356955,

10357416,

10364427,

10364323,

10372422, 10372987==

Procedures:

NMP-MA-014-001, Post Maintenance Testing Guidance, Vers. 4.1 & 4.2

FNP-1-STP-16.1, 1A Containment Spray Pump 1A Inservice Test, Ver. 48

NMP-ES-013-005, IST Implementation, Ver. 4.4

FNP-2-STP-11.2, 2B RHR Pump Quarterly Inservice Test, Ver. 42.0

FNP-0-EMP-2541.05,

MG-6 Lockout Relay Inspection, Ver. 5.0

FNP-0-EMP-2541.07,

MG-6 Lockout Relay Functional Test, Ver. 8.0

FNP-0-EMP-1311.07, Ver. 3

FNP-0-SOP-38.0-1C, Ver. 15

FNP-0-STP-80.2, Ver. 66.1

FNP-0-SOP-38.0, Ver. 126

FNP-1-STP-20.2, Ver. 25

Work Orders: SNC775429, SNC837488, SNC859060, SNC772675, SNC583447, SNC795521

Documents:

TE 983130

Fourth 10-Year Interval Pump Inservice Testing Basis Document, Ver. 4

Drawings: D-175038, Sheet 3, Ver. 27.0 U-166636, Ver. 1.0

D-175022, Ver. 30

==Section 1R22: Surveillance Testing Condition Reports:

10357876, 10357877==

Procedures:

FNP-2-STP-11.1, 2A RHR Pump Quarterly Comprehensive Inservice Test & Preservice Test, Ver. 45.0

FNP-2-STP-80.1, DG 2B Operability Test, Ver. 57.1

FNP-1-SOP-23.0, Ver. 94.2

FNP-0-SOP-0.0, Ver. 163

FNP-1-IMP-210.3, Ver. 13

FNP-0-ARP-19.2, Ver. 29

FNP-0-SOP-38.0, Ver. 126

FNP-0-SOP-38.0-2B, Ver. 14

Documents: ASME OM Code-2001, Code for Operation and Maintenance of Nuclear Power Plants

FNP-0-IMP-6.0 calibration data sheet for

FNP-HTG-8507, April 13, 2017

FNP-0-IMP-6.0 calibration data sheet for

FNP-HDTG-0010, April 14, 2017 Work Order SNC746917

Section 1EP2: Alert and Notification System Evaluation Procedures and Reports Southern Nuclear Company (SNC), Joseph M. Farley Nuclear Plant, Units 1 & 2, Emergency Plan, Versions 65 & 66

SNC Alert and Notification System (ANS) Design Report

NMP-AD-031-001, Reportability Requirements - Plant Specific - Farley Nuclear Plant, Version 4.0, pp. 44 & 45

NMP-EP-308, SNC Emergency Alert Siren Operation, Testing and Maintenance, Version 2.0

Emergency Information Calendar for 2017

WPS-2900 Series High Power Voice & Siren System Operating & Troubleshooting Manual,

2005

Records and Data Records of Silent, Full Cycle, and Growl ANS testing - January 1, 2015, to December 31, 2016 Siren System Report for SNC - Farley Plant system tests: 1/5/15; 2/2/15; 3/2/15; 4/6/15; 5/4/15; 6/4/15; 7/4/15; 8/4/15; 9/8/15; 10/5/15; 11/23/15;12/7/15; 1/7/16; 2/1/16; 2/8/16; 2/15/16; 2/22/16; 2/29/16; 3/7/17; 4/1/16; 5/2/16; 6/6/16; 6/7/16; 7/5/16; 8/1/16; 9/26/16; 10/3/16; 11/7/16;

& 12/5/16 FEMA acceptance letter, dated April 13, 2013

Documentation of ANS repair and annual preventative maintenance - January 1, 2015 to December 31, 2016

WPS-2900 Series High Power Voice & Siren System Operating & Troubleshooting Manual, 2005

Corrective Action Program Documents (Condition Reports)

CR 10011884, GEMA siren activation station networking

CR 10058195, Siren 19 showing low voltage, solar siren

CR 10068184, Siren 62 showing failed UHF and VHF

CR 10158375, Annual audible siren test

CR 10163672, Siren 2 showing activation failure and partial activation

CR 10238365, Siren 44 was reported to the Houston County EMA as actuating

CR 10255893, Siren 53 showing partial activation

Section 1EP3: Emergency Response Organization Staffing and Augmentation System Procedures

FNP-0-EIP-0.0, Emergency Organization, Version 31

FNP-0-EIP-6.0, TSC Setup & Activation, Version 48

FNP-0-EIP-8.3, Communications Equipment Operations Procedure, Version 18

FNP-0-EIP-10.0, Evacuation Personnel Accountability and Site Dismissal, Version 44

FNP-0-EIP-14.0, Emergency Response Teams, Version 30

FNP-0-TCP-50.2, Emergency Planning Controlled Functional Position Qualification Requirements, Version 13.0

NMP-EP-001, Corporate Emergency Response Organization, Version 8.2

NMP-EP-104, Dose Assessment, Version 8.0

NMP-EP-111, Emergency Notification, version 16

NMP-EP-111-001, Emergency Notification Communicator Instructions-Farley, Version 3.3

NMP-EP-112-001, Farley Site Specific PAR Instruction, Version 1.1

NMP-EP-112-GL01, Farley Site Specific PAR Development Tools, Version 1.0

NMP-EP-301, EOF Emergency Response Organization and Emergency Preparedness Staff Training, Version 9.0

Records and Data FNP Augmentation Drill Reports and test results, EOF/TSC Activation response times, 1Q15 - 4Q15 and 1Q16 - 4Q16 Emergency Response Organization current list On-call schedule, ERO memorandum, dated 2/16/17 Selected ERO Personnel Estimated Response Times Training Status Reports and training records for selected ERO individuals Minimum Staffing Levels, Emergency Plan, Revision 66, Table 3, pp. 1-2

Corrective Action Program Documents

CR 10071219, ERO muster meeting conference call

CR 10133753, Weekly Pager test

CR 10184724, ERO call-out software issues

CR 10270091, ENS Communicator not in muster meeting

CR 10276443, Cognitive trend identified - ERO Staffing

CR 10322409, Procedure enhancement for Fire Brigade response

Section 1EP4: Emergency Action Level and Emergency Plan Changes Procedures Joseph M. Farley Emergency Plan, Versions 65 & 66

NMP-EP-110, Emergency Classification Determination & Initial Action, Version 8.0

NMP-EP-110-GL01, FNP EALs - ICs, Threshold Values and Basis, Versions 10.0, 10.1, & 11.0

NMP-EP-111, Emergency Notifications, Version 11.0

NMP-EP-111-F01, Plant Farley Emergency Notification Completion Instructions, Versions 2.0 & 3.0

SM-96-1076-001,

NEI 99-01 EAL Calculations, Versions 2 & 3

SM-96-1076-002,

NEI 99-01 EAL Calculations, Version 5

Change Packages

FLT-15-011-01,

NMP-EP-100, Version 8.0, Screening/Evaluation, dated 5/28/15

FLT-15-018-01,

NMP-EP-111, Version 11.0, Screening/Evaluation, dated 8/18/15

FLT-15-019-01,

NMP-EP-111-F01, Version 2.0, Screening/Evaluation, dated 8/18/15

FNP-15-020-01,

NMP-EP-104, Version 8.0, Screening/Evaluation dated 12/4/16

FNP-15-018-03, Emergency Plan, Version 65, Screening/Evaluation, dated 2/24/16

FNP-15-021-01,

NMP-EP-111-F01, Version 3.0, Screening/Evaluation, dated 12/2/15

FNP-16-007-01, Emergency Plan, Version 65, Screening/Evaluation, dated 4/8/16

FNP-16-015-01,

NMP-EP-110-GL01, Version 10.0, Screening/Evaluation, dated 6/1/16

FNP-16-016-01,

NMP-EP-100-GL01, Version 11.0, Screening/Evaluation, dated 11/14/16

FNP-16-016-02, Emergency Plan, Version 66, Screening/Evaluation, dated 12/14/16

Section 1EP5: Maintenance of Emergency Preparedness Procedures

FNP-0-EIP-8.1, Emergency Phone Directory, Version 10.0

FNP-0-RCP-25, Radiation Protection Activities During a Radiological Accident, Version 46.0

NMP-EP-310, Maintaining the Emergency Plan, Version 4.1

NMP-GM-002, Corrective Action Program, Version 14.1

NMP-GM-002-001, Corrective Action Program Instructions, Version 35.3

NMP-GM-003, Self-Assessment & Benchmark Procedure, Version 23.1

Records and Data Current Letters of Agreement/Memorandums of Understanding EP Report - Crew 3 EP Drill (Off-Year Exercise), dated 11/20/15 EP Report - Plant Farley ALERT Declaration 11/1/16, dated 12/21/16 EP Report - 12/8/16 Drill, dated 1/17/17 EP Drill Report - Crew 3 TSC Mini-Drill, dated 10/27/15

EP Drill Report - Crew 3 SAMG Table Top Drill, dated 12/17/15 EP Drill Report - 1/27/16 Practice Exercise, dated 2/1/16 EP Drill Report - Biennial Exercise, dated 3/29/16

EP Drill Report - 8/26/16 Table Top Drill, dated 9/23/16 EP Drill Report - SAMG Table Top Drill, dated 2/6/17 EP Drill Report - 12/6/16 Off Sequence Radiological Monitoring Drill, dated 2/9/17

EP Proficiency Table Top Drill Results 1Q-2015, dated 4/2/15 EP Proficiency OSC Table Top Drill Results 2Q-2015, dated 8/6/15 EP Qualification Records for EP Personnel

FNP After-Action Report Pilcher's Ambulance Service/Southeast Alabama Medical Center, dated 5/12/15 FNP Potentially Contaminated Injured Individual (Annual Medical Drill), dated 12/17/15

NOS Audit of Emergency Preparedness, dated 2/18/16 NOS Audit of Emergency Preparedness, dated 2/9/17 Root Cause Determination Report, dated 2/8/17

Root Cause Determination Report, dated 3/20/17 Technical Evaluation

976650, NOUE Criteria Clarification Needed, dated 1/4/17

Corrective Action Documents

CR 10196768, Cognitive trend identified by CAPCOs - RSPS objective failures

CR 10260434, Evaluate applicability of Vogtle NRC violation for Farley

CR 10310967, NOUE criteria clarification needed

CR 10317142, TSC functionality assessment

CR 10317263, CFAM area of concern - timeliness of addressing fleet regulatory OE

CR 10324770, HU3 applicability

CR 10331271, Evaluate Basis in Rev. 6 EALs for clarity on seismic classifications

CR 10353951, Out-dated phonebook identified in FMT Kits (NRC identified)

CR 10353962, Out-of-date & missing inspection material provided to the NRC for off year inspection

Section 1EP6: Drill/Training Evaluation Procedures:

NMP-EP-110, Ver.8.1

NMP-EP-110-GL01, Ver.

NMP-EP-112, Ver. 5.1

NMP-EP-112-001, Ver. 1.1

Documents: Crew #4 Drill Controller/Evaluator Package, May 24, 2017

CR10369364

Section 4OA1: Performance Indicator Verification Procedures:

FNP-0-AP-54.0, Preparation and Reporting of NRC Performance Indicator Data and NRC Operating Data, Ver. 15.0

FNP-0-M-151.0, NRC Mitigating Systems Performance Index (MSPI) Basis Document, Ver. 12

NMP-AD-034, "Key Performance Indicators", Version 3.0

NMP-EP-310, Maintaining the Emergency Plan, Version 4.1

NMP-EP-311, SNC EP Tier 4 Performance Indicators, Version 2.0

NMP-ES-076, Mitigating System Performance Index Program (MSPI), Ver. 2.1

NMP-GM-013-002, Performance Assessment and Trending, Version 5.0

Documents: Farley Unit 1 CDE Margin Reports for Residual Heat Removal System, April 2016 to March 2017 Farley Unit 1 CDE Margin Reports for Cooling Water Systems, April 2016 to March 2017 Farley Unit 2 CDE Margin Reports for Residual Heat Removal System, April 2016 to March 2017 Farley Unit 2 CDE Margin Reports for Cooling Water Systems, April 2016 to March 2017

Farley Unit 1 MSPI UAI and URI Derivation Reports for Residual Heat Removal System, March 2017 Farley Unit 2 MSPI UAI and URI Derivation Reports for Residual Heat Removal System, March 2017 Farley Unit 1 MSPI UAI and URI Derivation Reports for Cooling Water Systems, March 2017

Farley Unit 2 MSPI UAI and URI Derivation Reports for Cooling Water Systems, March 2017

NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7

Records and Data DEP opportunities documentation for 1st, 2nd, 3rd, and 4th quarters 2016 Siren test data for 1st, 2nd, 3rd, and 4th quarters 2016 Drill and exercise participation records of ERO personnel for 1st, 2nd, 3rd, and 4th quarters 2016

Corrective Action Documents

CR 10354446, Evaluate DEP for 11/1/16 Alert

Section 4OA2: Problem Identification and Resolution Procedures:

NMP-AD-002, Problem Solving and Troubleshooting Guidelines, Ver. 12.0

NMP-GM-002, Corrective Action Program, Ver. 14.2

NMP-GM-013-002, Performance Assessment and Trending, Ver. 5.0

NMP-GM-002-001, Corrective Action Program Instructions, Ver. 35.4

Condition Reports:

10314018,

10316120,

10317122,

10319163,

10322476,

10322789,

10323400,

10323881,

10326048,

10326540,

10329836,

10331683,

10333713,

10344280,

10349704,

10353274,

10361298,

10363041,

10363373,

10365000,

10365136,

10368551,

10370217,

10372335,

10375259,

10377813,

10379845

Documents: TEs

978353,

977769,

977916,

977924,

977933, 268515

Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion Documents:

EN52374 A508622, Steam Flow Scaling Document - Unit 1, Ver. 20

CARs

267745,

267772 TEs

974543,

974743,

977622,

976699,

977978 WOs SNC826082, SNC828210, SNC828211

Event Recovery Report - Unit One Manual Reactor Trip due to Main Generator Load and Voltage Swinging, Nov. 26, 2016 Operator 4.0 Evaluation associated with

CR10302179, U1 Manual Reactor Trip on Nov. 27 MCR Logs Condition Reports:

10299704,

10299708,

10300717,

10309337,

10350840,

10302179,

10302188,

10302932,

10306023, 10322897

Section 4OA5: Other Activities Procedures:

FNP-0-MP-110.0, Dry Fuel Storage Campaign Guidelines, Ver. 16.0

FNP-0-MP-111.3, MPC Fuel Loading Operations, Ver 26.0

FNP-0-MP-111.12, Forced Helium Dehydration System Operation, Ver. 9.0

FNP-1-FHP-5.4, Spent Fuel Assembly Handling Tool, Ver. 24.0

FNP-0-STP-63.7, Spent Fuel Storage Cask Heat Removal System Monitoring, Ver. 20.1

NMP-RE-004, Irradiated Fuel Assembly and Core Component Inspection, Ver. 5.0

NMP-RE-006, Dry Cask Loading Verification, Ver. 1.1

Documents: Certificate of Compliance, Certificate No. 1014, Amendment 9, dated March 10, 2014

Dry Fuel Storage Operations Resource Guide

Condition Reports:

10341043,

10341859,

10346778,

10346921,

10346968,

10347848,

10350949,

10352091,

10354020,

10356025, 10369114