IR 05000348/2018010
| ML18355A262 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/20/2018 |
| From: | Omar Lopez-Santiago NRC/RGN-II/DRS/EB1 |
| To: | Madison D Southern Nuclear Operating Co |
| References | |
| IR 2018010 | |
| Download: ML18355A262 (14) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ber 20, 2018
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT - NRC DESIGN BASES ASSURANCE INSPECTION (PROGRAMS) REPORT NUMBER 05000348/2018010 AND 05000364/2018010
Dear Mr. Madison:
On November 8, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Joseph M. Farley Nuclear Plant Units 1 and 2 and the NRC inspectors discussed the results of this inspection with you and other members of your staff. On December 18, 2018, the inspectors re-exited the inspection results with Mr. Daniel Komm and other members of your staff. The results of this inspection are documented in the enclosed report.
NRC inspectors documented two findings of very low safety significance (Green) in this report.
These findings involved violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.
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 Farley Nuclear Plant. 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/
Omar López-Santiago, Chief Engineering Branch 1 Division of Reactor Safety Docket Nos. 50-348, 50-364 License Nos. NPF-2, NPF-8
Enclosure:
Inspection Report 05000348/2018010 and 05000364/2018010 w/ Attachment: Supplemental Information
Inspection Report
Docket Numbers: 50-348, 50-364 License Numbers: NPF-2, NPF-8 Report Numbers: 05000348/2018010 and 05000364/2018010 Enterprise Identifier: I-2018-010-0049 Licensee: Southern Nuclear Operating Company, Inc.
Facility: Joseph M. Farley Nuclear Plant, Units 1 and 2 Location: Columbia, Alabama Inspection Dates: October 22, 2018, to November 8, 2018 Inspectors: B. Davis, Senior Reactor Inspector (Lead)
T. Fanelli, Senior Reactor Inspector D. Kern, Senior Reactor Inspector M. Riley, Reactor Inspector Approved By: Omar López-Santiago, Chief Engineering Branch 1 Division of Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance at Joseph M. Farley Nuclear Plant, Units 1 and 2, by conducting a design bases assurance inspection (programs) 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 determine the full range of environmental conditions for motor control centers (MCCs) U & V Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green None 71111.21N-Systems NCV 05000348/2018010-01, Design 05000364/2018010-01 Bases Closed Assurance Inspection (Programs)
The NRC identified a Green finding and associated NCV of 10 CFR 50.49(d)(3) for the failure to determine the full range of environmental conditions that could occur during normal and accident circumstances in electrical penetration rooms for environmental qualification of MCCs U and V for Units 1 and 2.
Failure to replace or provide ongoing qualification for the Boston Insulated Wire (BIW) cables at the end of their qualified life Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green None 71111.21N-Systems NCV 05000348/2018010-02, Design 05000364/2018010-02 Bases Closed Assurance Inspection (Programs)
The NRC identified a Green finding and associated NCV of 10 CFR 50.49(e)(5) for the failure to replace safety related Boston Insulated Wire (BIW) cables at the end of their designated life unless ongoing qualification demonstrated that the cables had additional life.
INSPECTION SCOPE
Inspections were conducted using the appropriate portions of the inspection procedure (IP) 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, performed walk downs, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
===71111.21N - Design Bases Assurance Inspection (Programs)
The inspectors evaluated environmental qualification program implementation by reviewing the following components from October 22 - 26, 2018, and November 5 - 8, 2018:
Environmental Qualification (EQ) Program Components ===
1. Q1N23V011B, 1B Auxiliary Feedwater Motor Operated Stop Valve (Limitorque Valve Operator)2. Q2N11V001A, 2A Main Steam Isolation Valve (ASCO Solenoid Coil)3. Q2E11V025A, 2A Containment Sump Outlet Motor Operated Valve to Residual Heat Removal Pump 1A, (Limitorque Valve Actuator and Raychem Bolted Splice)4. Units 1 & 2 Motor Control Centers (MCCs) U & V
EQ Program Components Inside Primary Containment (3 Samples)
1. Q2B31V061, 2B Pressurizer PORV Solenoid Valve (ASCO Solenoid Coil)2. Q1E19C001A-B, 1A Post LOCA Containment Mixing Fan Motor (Joy-Reliance Motor)3. Units 1 & 2 Boston Insulated Wire and Cable Company (BIW) Cables with Neoprene Jacket, Mylar Shielding, and Ethylene Propylene Rubber (EPR) Insulation
INSPECTION RESULTS
Failure to determine the full range of environmental conditions for MCCs U & V Cornerstone Significance Cross-cutting Report Section Aspect Mitigating Systems Green None 71111.21N-Design NCV 05000348/2018010-01, Bases Assurance 05000364/2018010-01 Inspection (Programs)
Closed The NRC identified a Green finding and associated NCV of 10 CFR 50.49(d)(3) for the failure to determine the full range of environmental conditions that could occur during normal and accident circumstance in electrical penetration rooms for environmental qualification of MCCs U and V for Units 1 and 2.
Description:
For their environmental qualification (EQ) program, the licensee is committed to the Division of Reactor (DOR) guidelines for Unit 1 and NUREG 0588 CAT II for Unit 2. The licensee is committed to Regulatory Guide (RG) 1.89 for all replacement components for Unit 1. Each of these commitments, contain requirements for determining the service conditions including temperature, pressure, chemical, and humidity for which the electrical components could be exposed to during normal and accident conditions. The inspectors identified that the licensee failed to adequately establish the service conditions for motor controls centers (MCCs) U and V for Units 1 and 2 associated with a high energy line break (HELB).
The electrical rooms for the two trains of engineered safeguards, MCCs U & V, can be exposed to a harsh environment due to a high-energy line break (HELB) from a pipe rupture in the adjacent mechanical rooms. The environment in the electrical penetration and mechanical penetration rooms are able to communicate through twenty-four inch openings in the floor. The inspectors reviewed the HELB calculations for the mechanical rooms (17C-09, 26.06, 26.11, and 33.01) and verified that the rooms included in the calculations were exposed to harsh environments from pressure, steam, and chemicals (e.g. boron) from the postulated HELBs and critical cracks . The fluid systems involved in the analysis included the Steam Generator Blowdown (SGB) System, Chemical and Volume Control System (CVCS),and Boron Thermal Regenerative System (BTRS). Calculation 33.01 demonstrated that a HELB in the mechanical penetration rooms would increase the temperature, humidity, and pressure in the electrical penetration rooms where the MCCs are located. However, the licensee had not conducted a full analysis of the electrical penetration rooms to determine the environmental conditions resulting from a HELB. The licensee performed an initial review, RER SNC982750-01, to determine the impacts of a HELB on the electrical rooms and concluded the electrical rooms would reach a temperature of approximately 140 degrees Fahrenheit for approximately 1.5 minutes, humidity would increase to 90% for several hours, and pressure would increase to approximately 3 psi. In addition, trace amounts of boron could be carried by the steam into the MCCs and have the potential to corrode the components within the MCCs. The inspectors determined the equipment qualification package for MCCs U & V for both units, failed to establish the service conditions for temperature, humidity, pressure and chemical resulting from a HELB for environmental qualification.
Additionally, the inspectors noted that high differential pressure between the mechanical rooms and the adjacent hallway would initiate an automatic HELB isolation logic. From the HELB analysis, this isolation could range between 51 seconds and 170 seconds depending on the scenario. The calculation for isolation response time did not account for the volume of the ventilation system, which would increase the isolation response times and thus would increase the temperature, humidity, chemical, and pressure effects in the electrical rooms resulting from a HELB.
Corrective Actions: The licensee entered this issue into the corrective action program and performed an initial determination of operability. Based on environmental qualification data available for the components in the MCCs, the licensee determined the MCCs to be operable.
Corrective Action Reference: CR 10564610
Performance Assessment:
Performance Deficiency: The licensees failure to determine the environmental conditions for temperature, humidity, pressure, and radiation from the full range of operational and accident circumstances that could affect protection system equipment in electrical rooms, in accordance with DOR Guidelines, NUREG 0588, and RG 1.89 was a performance deficiency (PD).
Screening: The PD was determined to be more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of the safety related MCCs (U & V) that provide controls to power the MCCs components.
Specifically, the failure to verify that electrical components would remain functional under accident conditions adversely affected the reliability of that equipment when called upon.
Significance: The team used inspection manual chapter (IMC) 0609, Att. 4, Initial Characterization of Findings, issued December 7, 2016, for mitigating systems, and IMC 0609, App. A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, and determined the finding to be of very low safety significance (Green)because the finding was a deficiency affecting the qualification of a mitigating structure, system, and component (SSC), and the SSC maintained its operability.
Cross-cutting Aspect: No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Title 10 CFR 50.49(d)(3) required, in part,
- (d) for equipment important to safety the licensee shall include the information for
- (3) the environmental conditions, including temperature, pressure, humidity, and chemical at the location where the equipment must perform as specified.
Contrary to the above, from approximately 1981 to November 8, 2018, the licensee failed to establish the environmental conditions resulting from a HELB for MCCs U & V. Specifically, the licensee failed to account for temperature, humidity, and pressure conditions resulting from a HELB in the adjacent mechanical penetrations rooms when determining the environmental service conditions for MCCs U & V.
Enforcement Actions: This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy.
Failure to replace or provide ongoing qualification for the Boston Insulated Wire (BIW) cables at the end of their qualified life Cornerstone Significance Cross-cutting Report Section Aspect Mitigating Systems Green None 71111.21N-Design NCV 05000348/2018010-02, Bases Assurance 05000364/2018010-02 Inspection (Programs)
Closed The NRC identified a Green finding and associated NCV of 10 CFR 50.49(e)(5) for the failure to replace safety related BIW cables at the end of their designated life unless ongoing qualification demonstrated that the cables had additional life.
Description:
For their environmental qualification (EQ) program, the licensee is committed to the Division of Reactor (DOR) guidelines for Unit 1 and NUREG 0588 CAT II for Unit 2. The licensee is committed to Regulatory Guide (RG) 1.89 for all replacement components for Unit 1. Each of these commitments, contain requirements for determining the qualified life associated with the components service conditions.
The inspectors reviewed Equipment Qualification Package (EQP)-06, Rev. 9, which stated that the BIW cables had a forty-year qualified life at 90 °C. This was based on a thermal regression line for the EPR insulation provided by BIW. The inspectors noted that the regression line did not represent the EQ qualified life, but only demonstrated the thermal end of life condition where the cables were likely to fail under normal conditions from embrittlement and possible cracking. The regression line was for thermal aging alone and did not consider radiation, LOCA, or other effects for accident conditions at end of life. The inspectors reviewed BIW test report 73E0621, and found that it specified the accelerated aging criteria for the EQ qualified life. The report stated, in part, aging for 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> at 121
°C represents 40 years at 49 °C for the ethylene propylene rubber [EPR] insulation. By using the actual aging temperature and time specified in BIW test report 73E062 with the service temperatures for the cables, the inspectors determined that the actual qualified life was less than that determined by the licensee.
In addition, the inspectors reviewed NRC Information Notices, IN 87-65 and IN 89-30, which alerted licensees of potential problems resulting from high temperature hot spots in the environments around areas that contain safety-related equipment or electrical cables.
Accordingly, the licensee performed calculation E-1132 and determined that during certain times of the year, localized temperatures at the cables exceeded the temperature used for qualification. The licensee performed calculation ES 89-13503 to evaluate the effects of the ambient temperatures expected at the cables. Using the accelerated aging criteria from BIW report 73E062, the licensee determined that the qualified life for the BIW cables inside containment was approximately fourteen years and provided recommended replacement dates for both Units around the 1995 outages. The licensee had not replaced the cables or performed any ongoing qualification to demonstrate that the cabling systems had additional life. The inspectors determined that the BIW EPR cables inside containment exceeded the qualified life demonstrated acceptable by qualification report 73E062.
Prototype test summary report per letter sent to Mr. M. Malcolm of Bechtel Co. by J. Learn of Boston Insulated Wire on April 13, 1973 E-113, Qualified Life Calculation for EQ Equipment Located In-Containment, revision 42 ES 89-1350, Containment Temperature Monitoring Study, dated 10/16/1989 Corrective Actions: The licensee entered this issue into the corrective action program and performed an initial determination of operability. Based on test data available for EPR insulation and test data available for BIW Bostrad 7 cables, the licensee determined the cables are operable.
Corrective Action Reference: CRs 10560293 and 10553013
Performance Assessment:
Performance Deficiency: The licensees failure to maintain environmental qualification in accordance with the DOR Guidelines, NUREG 0588, and RG 1.89 was a PD.
Screening: The PD was determined to be more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of control and instrumentation cables that provide signals to components required to respond to initiating events. Specifically, the failure to address the qualified life of the cables in harsh environments, during which time they must perform a safety function, adversely affected the reliability of that equipment when called upon.
Significance: The team used inspection manual chapter (IMC) 0609, Att. 4, Initial Characterization of Findings, issued December 7, 2016, for mitigating systems, and IMC 0609, App. A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, and determined the finding to be of very low safety significance (Green)because the finding was a deficiency affecting the qualification of a mitigating structure, system, and component (SSC), and the SSC maintained its operability.
Cross-cutting Aspect: No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: 10 CFR 50.49(e)(5) required, in part, The equipment must be replaced or refurbished at the end of its designated life unless ongoing qualification demonstrates that the item has additional life.
Contrary to the above, from approximately 1995 to November 8, 2018, the licensee failed to replace or refurbish the BIW cables inside containment at the end of their designated life without any ongoing qualification that demonstrated the cables had additional life.
Enforcement Actions: This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
- On November 8, 2018, the inspectors presented the inspection results to Mr. Dennis Madison, and other members of the licensees staff.
- On December 18, 2018, the inspectors re-exited the inspection results to Mr. Daniel Komm, and other members of the licensees staff.
LIST OF
DOCUMENTS REVIEWED
CORRECTIVE ACTION DOCUMENTS WRITTEN AS A RESULT OF THE INSPECTION
10553001
10552422
10553013
10553071
10560293
10553127
10560293
10564610
PROCEDURES
FNP-1-ARP-1.5, Farley Nuclear Plant Annunciator Response Procedure Main Control Board
Annunciator Panel E Rev. 60.2
FNP-1-STP-213.16, Farley Nuclear Plant Surveillance Test Procedure High Energy Line Break
Instrumentation, Rev. 24.2
DRAWINGS
D-177627, 575 Motor Operated Valve, Sh. 24 Elementary Diagram, Rev. 2
D-207381, Unit 2 Pressurizer Pilot Operated Relief Valve Solenoid Valve Elementary Diagram,
Ver. 9.0
D-207863, Main Steam Isolation Valve Solenoid Valve Elementary Diagram, Ver. 13.0
U 205190, 3 - IA88RG Air Operated Control Valve (Q2B13V061)(Q2B13V053), Ver. 7.0
U-169344, 4 Globe Stop-Check Valve Pressure Seal-Welding Ends, Ver. 1.0
U-279106, 32 600#
D-177132 Elementary Diagram Containment Sump to RHR Pump 1A Isolation MOV, Rev. 9
D-205038, Sht. 2, Safety Injection System, Rev. 24
D-205143, Instrument Location, Auxiliary and Control Building Area Elevation 100 and Below,
Rev. 17
B-175810, Logic Diagram for Post LOCA Mixing Fan, Rev. 1
D-175146, J.M. Farley Nuclear Plant Unit No. 1 Instrument Location Auxiliary Building Area Plan
at 121-0, Rev. 33
D-205146, J.M. Farley Nuclear Plant Unit No. 2 Instrument Location Auxiliary Building Area Plan
at 121-0, Rev. 21
CALCULATIONS
E-104, Qualified Life of ASCO NP-1 Series Solenoid Valves Outside Containment, Rev. 16
E-113, Qualified Life Calculation for EQ Equipment Located In-Containment, Rev. 42
E-146, Qualified Life of EQ Equipment Located in Hot Spots in the Aux Building Rooms, Rev. 13
DOEJ-FR-C080591201-J001, Evaluation of Residual Heat Removal and Containment Spray
Encapsulated MOVs Operating in <100% Humidity as a Normal Environment, Rev. 1
B-148603, 14 Class 300 Motor Operated Gate Valve Assembly, Rev. 8
U-278948, Gate Valve 300#, Motor Operator 14 Class I, Q2E11V025A, Rev. 3
B-6, Dose Rates in Electrical Rooms 322 (2322) and 332 (2332) Resulting from
Containment Wall and Electrical Penetration Direct Shine, Rev. 0
17C-09, Aux Feed Water Pump Room to Compute Pressure and Temperature of the Turbine-
Driven Auxiliary Feed Pump Steam Line, Rev. 1
26.06, Temperature and Pressure Response Following a BTRS [Boron Thermal Regenerative
System] Alternate Letdown Line Break, Rev. 2
26.11, Pressure and Temperature Response of the Auxiliary Building to a CVCS [Chemical and
Volume Control System] Letdown Line Break, Rev. 3
33.01, Press / Temp Response of Aux Bldg to Breaks in SG [steam generator] Slowdown Line
After Addition of Porous Restrictors, Rev. 0
E-113, Qualified Life Calculation for EQ Equipment Located In-Containment, revision 42
ES 89-1350, Containment Temperature Monitoring Study, dated 10/16/1989
BM-95-0721-001, "Impact of Power Uprate on EQ and Shielding Analysis," Rev. 6
CORRECTIVE ACTION DOCUMENTS
10028658
2007-100142
798731
887262
WORK ORDERS
SNC479191
SNC511680
SNC390910
SNC390930
SNC431021
SNC454583
SELF ASSESSMENT REPORTS
2018 EQ DBAI Focused Area Self-Assessment (FASA), dated 7/9/2018
Miscellaneous Documents
B0058, Limitorque Valve Actuators Qualification for Nuclear Power Station Service Report,
dated 1/11/80
U-264740, IEEE 323 Qual Test of ASCO Solenoid, dated 9/14/81
U-266079, Qualification Test Report on Limitorque Valve Actuators with Type LR Motor, dated
9/19/88
U-266080, Test of Limitorque Valve Operator in Nuclear Reactor Containment Environment,
dated 9/19/88
U-402166A, Test Report ASCO Solenoid Valves, dated 9/16/87
U-402255, Qualified Life Based on Activation Energy, Component Replacement and
Surveillance PROG ASCO Catalog NP-1 Valves, dated 12/21/87
ER-364, Exploratory Test to Determine Mounting and Orientation Effects for NP Valves, dated
2/6/06
U-265679, Wyle Laboratories Environmental Qualification Test Report of Raychem WCSF-N In-
Line Bolted Splice Assemblies, dated 5/18/88
U-266078, Limitorque Valve Actuator Qualification for Nuclear Power Station Service Report
B0058, dated 1/11/80
U-279503, Wyle Laboratories Environmental Qualification Test Report of Raychem WCSF-N In-
Line Bolted Splice Assemblies, dated 5/18/88
U-359075, Westinghouse Flexible Wedge Gate Valve Vendor Manual, Rev. 0
U-400910A, Analysis of Heat Aging Data on WCSF Material to Determine Pre-Aging Conditions
for Nuclear Qualification Testing, dated 12/4/97
Joseph
- M. Farley Nuclear Plant, Unit 2, Master List of Environmentally Qualified Equipment,
Rev. 53
Joseph
- M. Farley Nuclear Plant, Updated Final Safety Analysis Report, Section 3.11, EQ
Program Environmental Conditions, Rev. 28
U-280317, Limitorque Valve Operator Instruction and Maintenance Manual, Rev. 8
EQP 0022, Environmental Qualification of Joy Containment Fan Motors, Rev. 10
EQP 23C, Equipment Qualification of Limitorque MOV Actuators Outside Containment and
Outside MSR, Rev. 19
EQP 29K, WCSF-N and NMCK In-Line Raychem Bolted Splice Assemblies (up to 1kV), Rev. 9
DCP1071559601, Unit 1 MCC Bucket Replacements, Rev. 7
DCR1072202901, Replace Selected MCC Cubicles in Unit 1 MCCs A and U, Rev. 0
DCR2071559701, Replace Selected MCC Buckets in Unit 2 MCCs U and V, Rev. 0
PS06-1023, Intercompany Correspondence, Joseph
Evaluate the Need for EQ Qualification of MCCs U and V, dated 5/10/2006
BIW-EQP6, Environmental Qualification Package No. 0006, Rev. 6
Submittal to NRC with BIW test report 73E062 as Attachment 2, dated 5/20/1983
Attachment