Text

NRC Integrated Inspection Report 05000348/2018001 and 05000364/2018001 and Exercise of Enforcement Discretion
	ML18128A010
Person / Time
Site:	Farley
Issue date:	05/08/2018
From:	Joel Munday; Division Reactor Projects II
To:	Madison D; Southern Nuclear Operating Co
References
	EA-18-025, EA-18-026 IR 2018001
	Download: ML18128A010 (24)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION May 8, 2018

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000348/2018001 AND 05000364/2018001 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Madison:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Joseph M. Farley Nuclear Plant, Units 1 and 2. On April 17, 2018, NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

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

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

Also, contrary to Technical Specifications (TS) 3.7.1 Main Steam Safety Valves (MSSVs), Unit 2 operated with a C loop main steam safety valve inoperable for longer than the TS allowed completion time due to the safety valve lifting above the TS required maximum set pressure during its as-found post-operational surveillance test. Although a violation of TS occurred, the violation was not within your ability to identify beforehand by reasonable licensee quality assurance measures or management controls. Therefore, the TS 3.7.1 violation was not associated with a licensee performance deficiency. The NRC concluded that the violation resulted in no or relatively inappreciable potential safety consequences because there was not an adverse impact on the main steam system over-pressurization protection safety function.

Based on these facts, I have been authorized after consultation with the Director, Office of Enforcement, and the Regional Administrator, to exercise enforcement discretion in accordance with Section 3.10 of the NRCs Enforcement Policy and refrain from issuing enforcement for the violation. This violation will not be considered in the assessment process of the NRCs Action Matrix.

In addition, contrary to TS 3.4.10, Pressurizer Safety Valves, Unit 2 operated with a pressurizer safety valve inoperable for longer than the TS allowed completion time due to the safety valve lifting below the TS required minimum set pressure during its as-found post-operational surveillance test. Although a violation of TS occurred, the violation was not within your ability to identify beforehand by reasonable licensee quality assurance measures or management controls. Therefore, the TS 3.4.10 violation was not associated with a licensee performance deficiency. The NRC concluded that the violation resulted in no, or relatively inappreciable, potential safety consequences because there was not an adverse impact on the reactor coolant system over-pressurization protection safety function. Based on these facts, I have been authorized after consultation with the Director, Office of Enforcement, and the Regional Administrator, to exercise enforcement discretion in accordance with Section 3.10 of the NRCs Enforcement Policy and refrain from issuing enforcement for the violation. This violation will not be considered in the assessment process of the NRCs Action Matrix.

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 05000348/2018001, 05000364/2018001

Inspection Report

Docket Number(s): 50-348, 50-364 License Number(s): NPF-2, NPF-8 Report Number(s): 05000348/2018001; and 05000364/2018001 Enterprise Identifier: 2018-001-0055 Licensee: Southern Nuclear Operating Company, Inc.

Facility: Joseph M. Farley Nuclear Plant Location: Columbia, Alabama Inspection Dates: January 1, 2018 to March 31, 2018 Inspectors: P. Niebaum, Senior Resident Inspector K. Miller, Resident Inspector J. Parent, Resident Inspector (1R04, 1R13, 1R22)

R. Cureton, Resident Inspector (1R12, 1R15)

D. Mas, Project Engineer (1R06, 1R19)

Approved By: Joel T. Munday, Director Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance by conducting baseline inspections at Joseph M. Farley, Units 1 and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC and self-revealed findings, violations, and additional items are summarized in the table below.

List of Findings and Violations Failure to conduct an In-Service Testing (IST) surveillance on the 2B charging pump discharge check valve Cornerstone Significance Cross-cutting Report Section Aspect Mitigating Green H.9 Training 71111.15 - Operability Systems Non-Cited Violation (NCV) Determinations and 05000364/2018001-01 Functionality Closed Assessments A Green self-revealed NCV of 10 CFR 50, Appendix B, Criterion XI, Test Control, was identified for the failure to test the 2B charging pump discharge check valve, Q2VE21V122B, in accordance with IST requirements. Specifically, licensee procedure FNP-2-STP-4.2, 2B Charging Pump Quarterly In-service Test was improperly signed off as complete in November 2017, without the required test being conducted. As a result, this was a missed opportunity to identify the degraded check valve which was later declared inoperable when it did not meet the surveillance test acceptance criteria on January 30, 2018.

PLANT STATUS

Unit 1 started the report period at approximately 100 percent rated thermal power (RTP). On March 26, Unit 1 shut down for main steam isolation valve (MSIV) maintenance, and remained shut down for the remainder of the inspection period.

Unit 2 started the report period at approximately 100 percent RTP. On February 17, a Unit 2 load reduction to 60 percent RTP occurred because of removal of a steam generator feedwater pump (SGFP) from service for maintenance. Following restoration of the SGFP to service, Unit 2 stabilized at approximately 100 percent RTP on February 18. Unit 2 remained at approximately 100 percent RTP until March 2, when a load reduction to 60 percent RTP occurred because of removal of a SGFP from service for maintenance. Following restoration of the SGFP to service, Unit 2 stabilized at approximately 100 percent RTP on March 3, and maintained approximately 100 percent RTP throughout the remainder of the inspection period.

INSPECTION SCOPES

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

REACTOR SAFETY

71111.01 - Adverse Weather Protection Seasonal Extreme Weather

Main article: IP 71111.01

The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold weather focusing on the 1C and the 2B emergency diesel generators.

71111.04 - Equipment Alignment Partial Walkdown

Main article: IP 71111.04

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

(1) Unit 1 - A spent fuel pool cooling train during 1B spent fuel pool pump maintenance on January 9, 2018

(2) Unit 1 - B train containment spray system while A train was inoperable for testing on January 9, 2018

(3) Unit 2 - 1-2A emergency diesel generator while the 2B emergency diesel generator was out of service for maintenance on February 27, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the Unit 2 600 Volt Alternating Current (AC) Emergency Load Centers on February 8, 2018.

71111.05AQ - Fire Protection Annual/Quarterly Quarterly Inspection

Main article: IP 71111.05AQ

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

(1) Fire Area 2-012, Fire Zone 2254 - Unit 2 Hot Shutdown Panel Room on February 5, 2018

(2) Fire Area 2-034, Fire Zone 2334 - Electrical Penetration Room, Train B on February 5, 2018

(3) Fire Area 2-035, Fire Zone 2333 - Electrical Penetration Room, Train A on February 5, 2018

(4) Fire Area 2-035, Fire Zone 2347 - Electrical Penetration Room on February 5, 2018

71111.06 - Flood Protection Measures Internal Flooding

Main article: IP 71111.06

The inspectors evaluated internal flooding mitigation protections in the Unit 1 Main Steam

===Valve Room (MSVR) on March 8, 2018.

Cables (1 Sample)===

The inspectors evaluated cable submergence protection in:

(1) Pull box 1WB1M54 on March 19, 2018.

71111.07 - Heat Sink Performance Heat Sink

Main article: IP 71111.07

The inspectors verified the readiness and availability of the 2C emergency diesel generator jacket water heat exchanger to perform its design function by reviewing eddy current testing and the licensees heat exchanger inspection reports on February 6, 2018. Additionally, the inspectors verified that the licensee entered any significant heat exchanger performance problems into the corrective action program and that the licensees corrective actions were appropriate.

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

Main article: IP 71111.11

The inspectors observed and evaluated a crew of licensed operators in the plants simulator during licensed operator requalification training on January 16, 2018.

Operator Performance (2 Samples)

(1) The inspectors observed and evaluated Unit 1 reactor operator performance without Main Control Room (MCR) annunciators during annunciator power supply replacement on February 7, 2018.

(2) The inspectors also observed and evaluated a Unit 2 load reduction to 97 percent RTP and a swap from the low pressure steam supply to the high pressure steam supply for the 2B steam generator feed pump on February 15, 2018.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness

Main article: IP 71111.12

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

(1) Unit 2, main steam safety valve lift pressure outside of technical specification limits

(2) Units 1 and 2, modification of the service water pump performance criteria for unavailability

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

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

(1) Unit 1 elevated risk due to 1A reactor coolant pump (RCP) degraded seal and pressurizer level controller troubleshooting on January 19, 2018

(2) Unit 2 elevated risk due to 2B residual heat removal (RHR) pump maintenance, 2C emergency diesel generator equipment outage, and 2B charging pump unavailability on January 30, 2018

(3) Unit 1 elevated risk during troubleshooting of charging flow control valve, Q1E21FCV122 on February 22, 2018

(4) Unit 2 elevated risk while the 2B emergency diesel generator was out of service for maintenance on February 28, 2018

71111.15 - Operability Determinations and Functionality Assessments

Main article: IP 71111.15

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 2 - Suspected degradation of power range nuclear instrument NI42 low voltage power supply on January 12, 2018

(2) Unit 2 - Past operability evaluation of steam flow/turbine impulse pressure transmitters on January 11, 2018

(3) Unit 1 - 1A RHR pump differential pressure adverse trend on March 12, 2018

(4) Unit 1 - A train service water mini-flow line weld leak on February 27, 2018

(5) Unit 2 - Past operability evaluation of the degraded 2B charging pump discharge check valve on February 10, 2018.

71111.18 - Plant Modifications

Main article: IP 71111.18

The inspectors evaluated the following temporary modification:

(1) Design Equivalent Change Package (DECP) SNC901880, Unit 2 C Service Water Minimum Flow Line Leak.

71111.19 - Post Maintenance Testing

Main article: IP 71111.19

The inspectors evaluated the following post maintenance tests:

(1) FNP-2-STP-247.1, Turbine Impulse Pressure PT446 Loop Calibration and Operational Test on January 12, 2018

(2) FNP-2-STP-247.2, Turbine Impulse Pressure PT447 Loop Calibration and Operational Test on January 12, 2018

(3) Work Order (WO) SNC917256, 2C Emergency Diesel Generator (EDG) jacket water heat exchanger tube bundle replacement on January 31, 2018

(4) WO SNC920122, Unit 2, pressurizer level signal comparator card replacement on January 25, 2018

(5) WO SNC921690, Unit 1, 1A component cooling water pump outboard bearing replacement on February 7, 2018

(6) WO SNC922691, Unit 2, Q2E21V0122B - 2B charging pump discharge check valve replacement on February 7, 2018

(7) WO SNC933133, Unit 2, Q2T53PENE86 - Containment Personnel Airlock Differential Pressure (D/P) detector replacement on March 20, 2018

71111.20 - Refueling and Other Outage Activities

Main article: IP 71111.20

The inspectors observed and evaluated the Unit 1 shutdown to Mode 4 and forced outage activities to repair an inoperable main steam isolation valve (MSIV) from March 26, 2018, through the end of the report period.

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Routine

Main article: IP 71111.22

(1) FNP-2-STP-80.1, Emergency Diesel Generator 2B Operability Test on January 2, 2018

(2) FNP-1-STP-11.2, 1B RHR Pump Quarterly In-service Test on January 22, 2018

(3) FNP-2-STP-22.16, Turbine Driven Auxiliary Feedwater Pump Quarterly In-service Test on February, 21, 2018

(4) FNP-1-STP-22.23, Turbine Driven Auxiliary Feedwater Pump Trip and Throttle Valve Indicator Operability Test on February 28, 2018.

In-service (1 Sample)

(1) FNP-1-STP-22.2, Auxiliary Feedwater Pump 1B In-service Test on January 4, 2018.

71114.06 - Drill Evaluation Emergency Planning Drill

Main article: IP 71114.06

The inspectors evaluated an emergency preparedness drill that involved the failure of the reactor to trip which led to an Alert Emergency, the loss of two fission product barriers which lead to a Site Area Emergency and the subsequent loss of the third barrier which led to a General Emergency on January 30,

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below for the period from January 2017 through December 2017

Main article: IP 71151

(1) unplanned scrams per 7,000 critical hours, IE01, both units

(2) unplanned power changes per 7,000 critical hours, IE03, both units

(3) unplanned scrams with complications, IE04, both units.

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues

Main article: IP 71152

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

(1) CR 10448087, Unanalyzed condition identified during transition to NFPA-805.

During the fire probabilistic risk assessment (PRA) circuit analysis review, the licensee identified that the Fire Safe Shutdown (SSD) analysis did not consider all fire-induced failures. The direct current (DC) control and 4 Kilovolts (KV) power cables for 37, 4KV safety bus breakers not credited for safe shutdown had not been analyzed. This total covered both Farley units. The licensee determined that fire damage to the unanalyzed circuits could result in a condition which could lead to opening of the 4KV safety bus normal feeder breakers required to be closed to achieve SSD for specific fire scenarios.

The DC control and power cables for the 37 unanalyzed safety bus breakers were contained within 14 total fire areas, some common and some for each unit. The licensee established compensatory fire watches and provided guidance to the operators to facilitate SSD procedural completion given occurrence of the condition. The inspectors reviewed the licensees evaluation of the issue and walked down several fire areas and determined that the issue did not represent a condition requiring additional inspection beyond baseline inspection. The licensees reanalysis of the impacted fire areas/zones determined the overall compartments risk was not significantly increased.

71153 - Follow-up of Events and Notices of Enforcement Discretion Events

Main article: IP 71153

The inspectors evaluated the issue associated with Event Notice (EN) # 53159 -

Unanalyzed Condition Identified during NFPA-805 Implementation and licensees response on January 10, 2018. Specifically, the inspectors verified adequate short term compensatory measures were implemented.

Licensee Event Reports (2 Samples)

The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report (LER) 05000364/2017-002-00, Main Steam Safety Valve Lift Pressure Outside of Technical Specification Limits, on November 1, 2017

(2) LER 05000364/2017-003-00, Pressurizer Safety Valve Setpoint Pressure Outside of Technical Specification Tolerance Band.

INSPECTION RESULTS

Enforcement Enforcement Action (EA)-18-025: Unit 2 Main Steam Safety 71153(1)

Discretion Valve (MSSV) Lift Pressure Outside of Technical Specification Limits

Description:

On October 26, 2017, MSSV Q2N11V0012E was removed from service at Farley Nuclear Plant Unit 2 during a refueling outage, and on November 1, 2017 the valve was tested with steam at an offsite facility. As-found lift testing determined that the valve opened at 1171 psig steam pressure, which was 9 psig high outside the plant technical specification (TS) allowable lift setting range of 1096 psig to 1162 psig. The valve had been in service prior to the plant beginning commercial operation on July 30, 1981, until it was removed from the main steam system on October 26, 2017. The licensee last tested the valve, while installed on the main steam system, on April 5, 2016. The test results indicated the lift pressure was within +/- 1% of the TS 3.7.1 required set pressure of 1129 psig, and no set pressure adjustment was necessary for the valve. The licensee determined that the MSSV high as-found lift set-point did not have an adverse impact on the main steam system over-pressurization protection, since the valve as-found lift setpoint was lower than 110% of steam generator design pressure (1194 psig), and this condition would not have resulted in a loss of safety function. Therefore, the plant remained bounded by the accident analysis in the Final Safety Analysis Report (FSAR), based on the as-found condition.

Corrective Action(s): The valve was replaced with an operable MSSV during the refueling outage prior to plant startup.

Corrective Action Reference(s): The licensee entered this issue into their Corrective Action Program (CAP) as condition report (CR) 10426186 - as found test results for MSSV Q2N11V0012E.

Enforcement:

Violation: Farley Nuclear Plant, Unit 2 Technical Specifications (TS) limiting condition for operation (LCO) 3.7.1, Main Steam Safety Valves (MSSVs), required five MSSVs per steam generator to be operable. Per TS Table 3.7.1-2, MSSV Q2N11V0012E must have a lift setting within the range of 1096 psig to 1162 psig, while the Unit was in modes 1, 2, and 3.

With one MSSV inoperable and the Moderator Temperature Coefficient (MTC) zero or negative at all power levels, Action Statement, Condition A, Required Action A.1, required reducing thermal power to 87% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . If the required action and associated completion time is not met, Action Statement, Condition C, required that the unit be in mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Contrary to the above, the licensee determined the MSSV setting was outside the TS limits longer than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months during the operating cycle between May 11, 2016 and October 15, 2017, while the Unit was in modes 1, 2, and 3.

Severity/Significance: The inspection assessed the severity of the violation using Section 6.1 of the Enforcement Policy and determined the significance is appropriately characterized at Severity Level IV, due to the inappreciable potential safety consequences. The significance of this violation was informed, in part, using IMC 0609, Appendix A, The Significance Determination Process (SDP) for findings at Power, dated June 19, 2012.

Basis for Discretion: The NRC exercised enforcement discretion in accordance with Section 3.10 of the Enforcement Policy because the MSSV as-found lift pressure issue was not reasonably foreseeable and preventable. The inspectors reached this conclusion due to the fact that the licensee last tested the valve satisfactorily, while installed on the main steam system, on April 5, 2016, and during the period of time that the valve was in service, following May 11, 2016, there was no indication of valve degradation (e.g. seat leakage).

Enforcement Enforcement Action (EA)-18-026: Unit 2 Pressurizer Safety Valve 71153(2)

Discretion Lift Pressure Outside of Technical Specification Tolerance Band

Description:

On October 26, 2017, pressurizer safety valve Q2B13V0031B was removed from service at Farley Nuclear Plant Unit 2, and on October 31, 2017 the valve was tested with steam at an offsite facility. As-found lift testing determined that the valve opened at 2455 psig steam pressure, which was low outside the plant technical specification allowable lift setting range of 2460 psig to 2510 psig. The valve had been installed and placed in service at Farley Nuclear Plant Unit 2 on April 22, 2013, and remained in service during three complete 18-month fuel cycles. Upon removal of valve Q2B13V0031B from Unit 2 on October 26, 2017, it was replaced with a similar operable refurbished valve. The licensee determined that the safety valve low as-found lift set-point did not have an adverse impact on reactor coolant system over-pressurization protection, since the valve continued to perform its reactor coolant system over-pressure protection function to prevent the system from exceeding the design pressure of 2485 psig. Therefore, the plant remained bounded by the accident analysis in the FSAR, based on the as-found condition.

Corrective Action(s): The valve was replaced with a similar operable refurbished valve during the refueling outage prior to plant startup.

Corrective Action Reference(s): The licensee entered this issue into their CAP program as CR10425733 - PZR safety valve test results.

Enforcement:

Violation: Farley Nuclear Plant Unit 2 TS LCO 3.4.10, Pressurizer Safety Valves, required three operable pressurizer safety valves with lift settings between 2460 psig and 2510 psig, while the Unit was in modes 1, 2, and 3. With one pressurizer safety valve inoperable, Action Statement, Condition A. Required Action A.1, required restoration of the valve to operable status within 15 minutes. If the required action and associated completion time is not met, Action Statement, Condition B, required that the unit be in mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Contrary to the above, the licensee determined the pressurizer safety valve setting was outside the TS limits longer than 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 15 minutes during the last operating cycle between May 9, 2016, and October 15, 2017, while the Unit was in modes 1, 2, and 3.

Severity/Significance: The inspection assessed the severity of the violation using Section 6.1 of the Enforcement Policy and determined the significance is appropriately characterized at Severity Level IV, due to the inappreciable potential safety consequences. The significance of this violation was informed, in part, using IMC 0609, Appendix A, The Significance Determination Process (SDP) for findings at Power, dated June 19, 2012.

Basis for Discretion: The NRC exercised enforcement discretion in accordance with section 3.10 of the NRCs Enforcement Policy because the pressurizer safety valve as-found lift pressure issue was not reasonably foreseeable and preventable. The inspectors reached this conclusion due to the fact that during the period of time that the valve was in service, following June 20, 2016, there were no main control room annunciators actuating for increasing pressurizer relief tank (PRT) pressure or safety valve tailpipe temperature. There was one occasion, on June 20, 2016, when there was evidence of possible seat leakage from valve Q2B13V0031B, based on main control room annunciators actuating for increasing pressurizer relief tank (PRT) pressure and safety valve tailpipe temperature. In addition, the low as-found lift set-point did not have an adverse impact on reactor coolant system over-pressurization protection, since the valve continued to perform its reactor coolant system over-pressure protection function to prevent the system from exceeding the design pressure of 2485 psig.

Failure to conduct an In-service Testing (IST) surveillance on the 2B charging pump discharge check valve Cornerstone Significance Cross-cutting Report Section Aspect Mitigating Green H.9 Training

==71111.15 - Systems NCV 05000364/2018001-01 Operability

==

Open/Closed Determinations and Functionality Assessments A Green self-revealed NCV of 10 CFR 50, Appendix B, Criterion XI, Test Control, was identified for the failure to test the 2B charging pump discharge check valve, Q2VE21V122B in accordance with IST requirements. Specifically, licensee procedure FNP-2-STP-4.2, 2B Charging Pump Quarterly In-service Test, was improperly signed off as complete in November 2017, without the required test being conducted. As a result, this was a missed opportunity to identify the degraded check valve which was later declared inoperable when it did not meet the surveillance test acceptance criteria on January 30, 2018.

Description:

During the performance of licensee procedure FNP-2-STP-4.2, 2B Charging Pump Quarterly In-service Test on January 30, 2018, it was discovered that the pumps discharge check valve, Q2E21V122B, did not meet the acceptance criteria to limit a pressure rise of less than or equal to five psig. The actual pressure rise was seven psig. This indicated that the pump discharge check valve was not properly limiting reverse flow through the valve as expected. The downstream manual isolation valve, Q2E21V123B was maintained in the closed position to maintain the operability of the 2A and 2C charging pumps. The valve was replaced with a new similar check valve and tested satisfactorily on February 10, 2018.

The inspectors determined that the quarterly test for this check valve was not conducted as required in November 2017. Instead, licensee procedure FNP-2-STP-4.11, Charging Pump Biennial Comprehensive In-service Test, was performed which the licensee credited toward completion of the required quarterly in-service test (FNP-2-STP-4.2). However, the biennial in-service test does not perform the reverse flow test of the discharge check valve. The inspectors concluded that this was a missed opportunity to identify the degraded check valve and implement necessary corrective actions that could have prevented the valve from being declared inoperable on January 30, 2018. According to the licensees Fourth 10-Year Interval Valve In-service Testing Basis Document, Ver. 5, the 2B charging pump discharge check valve, Q2E21V122B is required to be tested quarterly in the closed (checked) direction in accordance with licensee procedure FNP-2-STP-4.2.

Corrective Action(s): The check valve (V122B) was isolated from the 2A and 2C charging pumps by maintaining the downstream manual isolation valve (V123B) closed. The valve was replaced with a new similar check valve and post maintenance testing was conducted satisfactorily on February 10, 2018.

Corrective Action Reference(s): The licensee entered this issue into their CAP program as CR10456229 and CR10465582.

Performance Assessment:

Performance Deficiency: Failure to conduct a quarterly surveillance test of the 2B charging pump discharge check valve as required by the IST program was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At Power, dated July 1, 2012. The finding screened very low safety significance (green), because it was not a deficiency affecting the design or qualification of a mitigating structure, system or component (SSC); did not represent a loss of system and/or function; did not represent an actual loss of function of at least a single train for more than its technical specification allowed outage time; and did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety significant in accordance with the licensees maintenance rule program for more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Cross-cutting Aspect: The inspectors determined the finding had a cross-cutting aspect of Training in the Human Performance area because the individual(s) involved were not aware of the requirements that have to be met when one surveillance is used to take credit for another [H.9].

Enforcement:

Violation: 10 CFR 50, Appendix B, Criterion XI, Test Control, required in part a test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures.

Contrary to the above, from November 1, 2017 until January 30, 2018, the licensee failed to properly test the 2B charging pump discharge check valve (Q2E21V122B) in the closed direction as required by the licensees Fourth 10-Year Interval Valve In-service Testing Basis Document, Ver. 5. As a result, there was a missed opportunity to identify the degraded check valve and implement necessary corrective actions to prevent the valve from being declared inoperable during the quarterly surveillance test on January 30, 2018.

Disposition: This violation is being treated as a non-cited violation (NCV), 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 April 17, 2018, the inspectors presented the quarterly baseline inspection results to Mr. Dennis Madison and other members of the licensee staff.

DOCUMENTS REVIEWED

71111.01: Adverse Weather Protection

Procedures:

FNP-0-SOP-0.12, Cold Weather Contingencies, Ver. 23

FNP-1-EMP-1383.01, Freeze Protection Inspections, Ver. 23

NMP-GM-025, Seasonal Readiness Process, Ver. 4.1

FNP-0-STP-63.5, HVAC Verification for Diesel Generator Building, Ver. 18.1

Condition Reports:

10444407, 10444409, 10429181, 10429439, 10442265, 10446689, 10446688

Documents:

Work Orders: SNC494960, SNC843114, SNC827872

FNP-0-SOP-0.12, Attachment 1 for Jan. 2, 2018

FNP-0-SOP-0.12, Attachment 1 for Jan. 3, 2018

Admin Tracking Item (ATI) # 1126, dated August 6, 2013

71111.04: Equipment Alignment

Drawings:

D-175043, Unit 1, P&ID - Spent Fuel Pool Cooling System, Ver. 30

D175038, Sht. 1, Unit 1, P&ID - Safety Injection System, Ver. 44.0

D175038, Sht. 3, Unit 1, P&ID - Safety Injection System (Containment Spray), Ver. 27.0

D207001, Unit 2 Single Line - Electrical Auxiliary System (Emergency 4160V & 600V), Ver.

2.0

D207005, Unit 2 Single Line Protection and Metering - 4160V Switchgear Bus 2F (Emergency),

Ver. 14.0

D207006, Unit 2 Single Line Protection and Metering - 4160V Switchgear Bus 2G (Emergency),

Ver. 18.0

D207018, Unit 2 Single Line Protection and Metering - 4160V Switchgear Bus 2H (Emergency),

Ver. 11.0

D207027, Unit 2 Single Line Protection and Metering - 4160V Switchgear Bus 2J (Emergency),

Ver. 9.0

D207043, Unit 2 Single Line Protection and Metering - 4160V Switchgear Bus 2K (Emergency),

Rev. 2

D207044, Unit 2 Single Line Protection and Metering - 4160V Switchgear Bus 2L (Emergency)

Rev. 2

D-170800, P&ID - Lube Oil System for Diesel Generator 1-2A, Ver. 14

D-170802, P&ID - Intercooler Water System for Diesel Generator 1-2A, Ver. 12

D-170804, P&ID - Jacket Coolant System for Diesel Generator 1-2A, Ver. 20

D-170806, P&ID - Air Start System for Diesel Generator 1-2A, Ver. 22

D-170808, P&ID - Fuel Oil System for Diesel Generator 1-2A, Ver. 12

Procedures:

FNP-1-SOP-54.0A, Spent Fuel Pit Cooling and Purification System, Ver. 15

FNP-1-SOP-54.0, Spent Fuel Pit Cooling and Purification System, Ver. 74

FNP-1-SOP-9.0A, Containment Spray System, Ver. 9.0

FNP-1-SOP-9.0, Containment Spray System, Ver. 40.1

FNP-2-SOP-36.0, Plant Electrical Line-Up, Ver. 10.0

FNP-2-SOP-36.3, 600, 480, and 208/120 Volt AC Electrical Distribution System, Ver. 30.0

FNP-2-SOP-36.3A, 600, 480, and 208/120 Volt AC Electrical Distribution System, Ver. 44.1

FNP-0-STP-80.1, Diesel Generator 1-2A Operability Test, Ver. 72

FNP-0-SOP-38.0A, 1-2A Diesel Generator, Ver. 18

FNP-0-SOP-38.0-1-2A, 1-2A Diesel Generator and Auxiliaries, Ver. 18.2

Condition Reports:

10448065

71111.05AQ: 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

D356848, Unit No. 2 - Fire Barriers and Fire Boundaries - U2 Auxiliary Building and

Containment El. 130 & 139, Ver. 1.0

Documents:

A-181805, NFPA 805 Fire Protection Program Design Basis Document, Ver. 4.0

WO SNC601721, FNP-2-FSP-63.2, Visual Inspection of Penetration Fire Barriers (Auxiliary

Building: 121 El. Walkway, Computer Room, Hot Shutdown Panel Room, Corridor, Ver. 5.0

WO SNC687788, FNP-2-FSP-63.16B, Visual Inspection of Penetration Fire Barriers Train B

(Auxiliary Building - Electrical Penetration Rooms), Ver. 2.1

WO SNC687792, FNP-2-FSP-63.16, Visual Inspection of Penetration Fire Barriers (Auxiliary

Building - Electrical Penetration Rooms), Ver. 6.1

WO SNC700265, FNP-2-FSP-63.16A, Visual Inspection of Penetration Fire Barriers Train A

(Auxiliary Building - Electrical Penetration Rooms, Ver. 2.1

WO SNC85977, FNP-2-FSP-65.0A, Fire Doors and Dampers Functional Inspection Train B, Ver.

3.0

WO SNC539281, FNP-2-FSP-65.0B, Fire Doors and Dampers Functional Inspection Train A, Ver.

4.0

WO SNC71607, FNP-2-FSP-41.3, Fire Dampers - Functional Test, Ver. 12.0

WO SNC551692, FNP-2-FSP-41.1, Fire Dampers - Functional Test (Penetration Room Filtration

System), Ver. 13.0

WO SNC808170, FNP-0-FSP-58.0, Fire Hose Stations, Ver. 12.0

WO SNC840934, FNP-0-FSP-58.0, Fire Hose Stations, Ver. 12.0

WO SNC644351, FNP-2-FSP-207.0, Hose Station Flow and Valve Functionality Test, Ver. 4.1

WO SNC724663, FNP-2-FSP-65.2, Fire Doors Functional Inspection Auxiliary Building, Ver. 14.0

WO SNC563240, FNP-1-FSP-65.2, Fire Doors Functional Inspection Auxiliary Building - Diesel

Building - Service Water Building, Ver. 9.0

WO SNC779004, FNP-1-FSP-65.2, Fire Doors Functional Inspection Auxiliary Building - Diesel

Building - Service Water Building (Non Train Related), Ver. 16.1

WO SNC776088, FNP-1-FSP-65.2A, Fire Doors Functional Inspection Auxiliary Building - Diesel

Building - Service Water Building Train A, Ver. 7.0

WO SNC609474, FNP-1-FSP-65.2A, Fire Doors Functional Inspection Auxiliary Building - Diesel

Building - Service Water Building Train A, Ver. 3.0

WO SNC638247, FNP-2-FSP-307.0, Smoke Detectors - Biennial Operability and Adjustment,

Ver. 22.0

WO SNC609590, FNP-2-FSP-307.0, Smoke Detectors - Biennial Operability and Adjustment,

Ver. 22.0

WO SNC638320, FNP-2-FSP-307.0, Smoke Detectors - Biennial Operability and Adjustment,

Ver. 22.0

WO SNC668553, FNP-2-FSP-405.0, Preaction Sprinkler System (Annual), Ver. 19.0

Procedures:

FNP-2-FPP-1.0, Unit 1 Auxiliary Building Pre-Fire Plan, Ver. 1.0

71111.06: Flood Protection Measures

Documents:

WCAP-15560, Units 1 and 2 Main Steam Valve Room Analysis for Steamline Breaks Outside

Containment, Feb. 2001

U-262880 - Level Switch - Gems, December 7, 1987

Procedures:

FNP-1-STP-215.7, Flooding Detector Q1N21LSH2828A, B, C and Q1N21LSH2829A, B, C

Functional Test, Ver. 17

NMP-ES-051-004, Pull Box Inspection Procedure, Ver. 5.1

Drawings:

D-175005, P&ID - Auxiliary Building Drains Non-Rad., Ver. 28

D-177500, Elementary Diagram Main Steam Valve Room Flooding Sensors, Rev. 2

D-172224, Joseph M. Farley Nuclear Plant Unit 1 Outdoor Ducts-Class 1-Valve Boxes to

Snubber Test BLDG & Reactor Refueling Storage Tank, Sheet 1, Rev. 5

C-172466, Farley Nuclear Plant Unit 1 & Development of Pull Box B1M54, Rev. 2

A-177541, Joseph

M. Farley Nuclear Plant Tray & Conduit Details & Notes, Sheet 3 of 29,

Rev. 16

Condition Reports:

CR 10437722, 104373612, 104373635, 104373648, 10465503, 10470554

71111.07: Heat Sink Performance

Procedures:

NMP-ES-012, Heat Exchanger Program, Ver. 11.0

NMP-ES-012-GL01, Heat Exchanger Program Heat Exchanger Inspection, Testing and

Condition Assessment, Ver. 5.0

Documents:

NDE Technology Inspection Summary report for Farley Unit 2, 2C Diesel generator Jacket

Water Cooler - QSR43H0509, December 2017

CR #1001698, Bridging Strategy for the EDG JW and IC HXs

WO SNC917256, Replace 2C Diesel Generator Jacket Water Heat Exchanger Tube Bundle

SM-97-1505-001, PROTO-HX Small and Large Diesel Generator Models, Ver. 6

71111.11: Licensed Operator Requalification Program

Documents:

Troubleshooting Log - 2B SGFP Reheat Steam Isolation Valve, February 15, 2018

F-LT-SG-18-S0102, Licensed Operator Continuing Training Simulator Exercise Guide for LOCT

16-18, Segment 17-2, Ver. 1

Unit 1 compensatory measures during operation without MCR annunciators while an annunciator

power supply was replaced

Procedures:

NMP-TR-416, Licensed Operator Continuing Training Program Administration, Ver. 8

NMP-TR-416-001, Plant Farley Licensed Operator Continuing Training Program Instruction,

Ver. 8

71111.12: Maintenance Effectiveness

Documents:

N11-F06, MR PMG Details - Reliability Criteria - MSSVs

N11-F06, MR Function Scoping Document for MSSVs

CAR 271701, Corrective Action Report - Cause & Resolution of MSSV Test Results

TE 997833, Technical Evaluation - MR Evaluation

MR expert panel meeting #18-03 agenda, date February 28, 2018

P-16-F02, MR function scoping documents for service water pumps

EVAL-F-P16-04229, MR (a)(1) plan for service water pumps

MR expert panel meeting #18-04 Agenda, date March 21, 2018

Condition Reports:

10433852

Procedures:

NMP-ES-027, Maintenance Rule Program, Ver. 7.0

71111.13: Maintenance Risk Assessments and Emergent Work Evaluation

Procedures:

NMP-GM-031, On-Line Configuration Risk Management Program, Ver. 5

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

NMP-GM-031-003, Risk Management Actions for 10 CFR 50.65(a)(4) and the Risk Informed

Completion Time Program, Ver. 4

NMP-DP-001, Operational Risk Awareness, Ver. 15

NMP-DP-001-GL01, Risk Assessment Worksheets, Ver. 11.1

NMP-OS-010, Protected Train/Division and Protected Equipment Program, Ver. 8

NMP-OS-010-001, Farley Protected Equipment Logs, Ver. 15

Condition Reports:

10462736

Documents:

Unit 1 Operators Risk Report (EOOS) for January 19, 2018

Unit 1 Operators Risk Report (EOOS) for February 22, 2018

Unit 2 Operators Risk Report (EOOS) for February 28, 2018

71111.15: Operability Determinations and Functionality Assessments

Drawings:

U-207610, Schematic Diagram Turbine 1st Stage Pressure Protection III, Rev. 0

U-207616, Schematic Diagram Turbine 1st Stage Pressure Protection IV, Rev. 0

U-207614, Schematic Diagram - Steam and Feedwater Loop 2 Protection III, Ver. 1

D-205038, Unit 2 P&ID - Safety Injection System, Ver. 39

D-205039, Unit 2 P&ID - Chemical and Volume Control System, Ver. 10

Documents:

Work Orders (WO) SNC685010, SNC685355, SNC836446

Unit 2, Main Control Room Logs, Nov. 21, 2017 & January 11, 2018

Unit 1, Main Control Room Logs, September 19, 2017, December 11, 2017 and March 3, 2018

Administrative Tracking Item #1984

Tagout: 1-ST-18-P16-00028

ALA-16-112, J.M. Farley Units 1 & 2 Charging/Safety Injection Check Valve Leakage

Acceptance Criteria, December 20, 2016

ALA-08-97, Transmittal of Throttle Valve Replacement Analysis Summary, November 4, 2008

SNC544433, Performance of FNP-2-STP-4.11, Ver. 10 on November 1, 2017

ALA-18-10, Transmittal of LTR-SEE-18-52, Evaluation of Farley Charging Pump 2B Check

Valve Leakage, March 20, 2018

SNC551355, Performance of FNP-2-STP-40.7, Vers. 32 and 33, November 9, 2014

SNC857211, Performance of FNP-2-STP-4.2, 2B Charging Pump Quarterly In-service Test, Ver.

80, February 10, 2018

Unit 2 Fourth 10-Year Interval Valve In-service Testing Basis Document, Ver. 5

Procedures:

FNP-2-STP-41.3, Power Range Functional Test Channels (N-41, N-42, N-43), Ver. 35.2

FNP-2-STP-109.1, Power Range Neutron Flux Channel Calibration Using the Plant Computer,

Ver. 40

FNP-2-ETP-4462.0, Power Ascension Following a Unit Refueling Outage, Ver. 11

FNP-1-STP-11.1, 1A RHR Pump Quarterly In-service Test, Ver. 62

NMP-GM-006-002, Surveillance/PM Program, Ver. 1.3

FNP-2-STP-4.2, 2B Charging Pump Quarterly In-service Test, Ver. 78

Condition Reports:

10448927, 10450794, 10449172, 10449119, 10470270, 10466934, 10465582, 10456229

71111.18: Plant Modifications

Drawings:

DECP SNC901880SKM001, Partial Penetration Weld Details, Ver. 1.0

DECP SNC901880SKM002, Longitudinal Weld Details, Ver. 1.0

DECP SNC901880SKM003, Reinforcement Sleeve Details, Ver. 1.0

DECP SNC901880SKM004, Reinforcement Sleeve Details, Ver. 1.0

DECP SNC901880SKM005, Backing Strip Fabrication Details, Ver. 1.0

SNC901880AWA001, Weld Map for WO904008

D200013, Unit 2 - P&ID - River Water, Service Water and Circulating Water, Sheet 2, Ver. 23.0

D515078, Unit 2 - River Water & Service Water Intake System - P16 - Piping & Hanger

Isometric, Rev. 1.0

Procedures:

NMP-ES-084-005-F02, Temporary Configuration Change Installation Checklists, Ver. 2.1

NMP-ES-024-401, Magnetic Particle Examination Record, Ver. 10.0

FNP-0-SPP-4.0, Welding Procedure Specifications, Ver. 2.0

FNP-0-SPP-1.1, Post Weld Heat Treatment, Ver. 3.1

NMP-MA-052, Repair/Replacement Program, Ver. 1.0

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

NMP-AD-009, Licensing Document Change Requests, Ver. 13.4

NMP-ES-018, SNC In-service Inspection Engineering Program, Ver. 11.0

Documents:

SNC901880AWA001, WO SNC904008, Advanced Work Authorization Form, Ver. 3.0

WO SNC904008

Design Equivalent Change Package (DECP) SNC901880, Unit 2 C Service Water Minimum

Flow Line Leak, Rev. 1.0

Form WD-012, Work Sequence Completion Checklist (3/2008) for WO SNC904008

Form WD-010A, Weld Process Control Sheet - Groove (3/2008) for WO SNC904008

Form WD-010B, Weld Process Control Sheet - Fillet/Socket (3/2008) for WO SNC904008

NMP-ES-084-005-F02, Temporary Configuration Change Installation Checklists, for WO

SNC904008, Ver. 2.1

NMP-ES-024-401, Magnetic Particle Examination Record, As Welded for WO SNC904008, Ver.

10.0

NL-17-1769, Joseph M. Farley Nuclear Plant Unit 1 - Proposed ISI Alternative FNP-ISI-ALT-22

Implementation of Code Case N-786-1, Version 1.0, dated October 24, 2017

(ML17299A685)

NRC Safety Evaluation by the Office of Nuclear Reactor Regulation - Proposed ISI Alternative

FNP-ISI-ALT-22 Implementation of Code Case N-786-1, Version 1.0, dated November 1,

2017 (ML17298A416)

NMP-AD-009-F01, Licensing Document Change Request (LDCR) No. 2017-050, Service Water

ISI Alternative for N-786-1, Ver. 1.0

NMP-AD-009-F02, LDCR Impact Review, LDCR No. 2017-050, Service Water ISI Alternative for

N-786-1, Ver. 1.0

DOEJ-FDSNC9071880-S001, Evaluation of Additional Weight on Service Water Piping in Stress

Calculation 0864 (Farley Unit 2), Ver. 2.0

DOEJ-FDSNC901880-S001, Evaluation of Code Case N-781-1 Piping Sleeve on Service water

Piping in Stress Calculation 0864 (Farley Unit 2), Ver. 2.0

NMP-AD-008-F01, Applicability Determination, SNC901880, Ver. 1.0

NMP-AD-010-F01, 10 CFR 50.59 Screening/Evaluation, SNC901880, Ver. 1.0

ES-EP-003, Alternative FNP-ISI-ALT-22, Version 1.0, 10 CFR 50.55a Evaluation, Rev. 0