IR 05000348/2019011
| ML19093A501 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 04/03/2019 |
| From: | Alan Blamey NRC/RGN-II/DRP/RPB2 |
| To: | Kharl C Southern Nuclear Operating Co |
| Geanette D | |
| References | |
| EA-17-204 IR 2019011 | |
| Download: ML19093A501 (13) | |
Text
ril 3, 2019
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT - NUCLEAR REGULATORY COMMISSION PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000348/2019011 AND 05000364/2019011
Dear Mr. Kharl:
On May 1, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Farley Nuclear Plant, Units 1 and 2, and discussed the results of this inspection with Dennis R. Madison and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No NRC-identified or self-revealing findings of more than minor significance were identified during this inspection. 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/
Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos.: 05000348 and 05000364 License Nos.: NPF-2 and NPF-8
Enclosure:
Inspection Report 05000348/2019011 and 05000364/2019011
Inspection Report
Docket Number(s): 05000348 and 05000364 License Number(s): NPF-2 and NPF-8 Report Number(s): 05000348/2019011 and 05000364/2019011 Enterprise Identifier: I-2019-011-0027 Licensee: Southern Nuclear Operating Co., Inc.
Facility: Farley, Units 1 and 2 Location: Birmingham, AL 35242 Inspection Dates: February 03, 2019 to February 22, 2019 Inspectors: P. Meier, Senior Resident Inspector N. Pitoniak, Sr. Fuel Facility Project Inspector C. Safouri, Resident Inspector Power N. Staples, Senior Project Engineer Approved By: Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting the biannual inspection of the licensees corrective action program at 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. Findings and violations being considered in the NRCs assessment are summarized in the table below.
List of Findings and Violations No findings were identified.
Additional Tracking Items Type Issue number Title Report Status Section NOV 05000364,05000348/2018014- Failure to Complete 71152B (Close)01 System Operator Rounds as Required per Procedures NOV 05000364,05000348/2018014- Failure to Provide 71152B (Close)02 Complete and Accurate Information Related to System Operator Rounds
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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution 02.04 Biennial Team Inspection
The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems.
- Operating Experience, Self-Assessments and Audits - The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
- Safety Conscious Work Environment - The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B 1. Corrective Action Program Effectiveness Based on the samples reviewed, the team determined that the licensees corrective action program (CAP) complied with regulatory requirements and self-imposed standards. The licensees implementation of the CAP adequately supported nuclear safety.
Problem Identification The team determined that most conditions that required generation of a condition report (CR)by licensee procedure, NMP-GM-002, Corrective Action Program, had been appropriately entered into the corrective action program (CAP). The team observed supervisors at the Management Review Committee (MRC) meetings and CR Screening meetings appropriately questioning and challenging condition reports to ensure clarification of issues and appropriate entry into the corrective action program. In response to observations identified by the team during plant walkdowns, licensee personnel initiated condition reports and/or took immediate action to address the issues. Based on the samples reviewed, the team determined that the licensee trended equipment and programmatic issues, and appropriately identified problems in condition reports. Additionally, the team concluded that personnel were identifying trends at low levels. Overall, the team determined that the licensee is identifying problems at the proper threshold and entering them into the corrective action program.
Problem Prioritization and Evaluation Based on the review of CRs sampled by the inspection team during the onsite period, the team concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in NMP-GM-002-GL03, Cause Analysis and Corrective Actions Guidelines." Operability and reportability determinations were performed when conditions warranted, and the evaluations generally supported the conclusions as described in NMP-AD-012, Operability Determinations and Functionality Assessments. The causal analyses reviewed appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue. In general, the team determined the technical adequacy and depth of evaluations was appropriate. Overall, the team determined that the licensees process for evaluating and prioritizing issues once they had been entered into the corrective action program supported nuclear safety.
Effectiveness of Corrective Actions For Significant Conditions Adverse to Quality (SCAQ), corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, CRs, and effectiveness reviews demonstrated that significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence (CAPRs)were generally sufficient to ensure corrective actions were properly implemented and were effective. The team reviewed green findings since the last PI&R biennial inspection along with CRs written to document the findings. The team found that CRs had adequate corrective actions in place, completed actions were closed, and open actions had reasonable dates for completion. Based on review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the team determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected and non-recurring.
Assessment 71152B
2. Use of Operating Experience
Based on a review of selected documentation related to OE issues, the team determined that the licensee was generally effective in screening operating experience for applicability to the plant. Industry OE was evaluated at either the corporate or plant level depending on the source and type of document. Relevant information was then forwarded to the applicable department for further action or informational purposes. Operating Experience issues requiring action were entered into the CAP for tracking and closure.
Assessment 71152B
3. Self-Assessments and Audits
The team determined that the scopes of assessments and audits were adequate. Self-assessments were generally detailed and critical. The team verified that CRs were created to document areas for improvement and findings resulting from self-assessments, and verified that actions had been completed consistent with those recommendations. Audits of the quality assurance program appropriately assessed performance and identified areas for improvement. Generally, the licensee performed evaluations that were technically accurate.
4. Safety Conscious Work Environment
Based on the interviews conducted and the CRs reviewed, the inspectors determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees. Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.
NOV Failure to Complete System Operator Rounds as Required 71152B (Closed) per Procedures 05000364,05000348/2018014-01
Description:
The team reviewed the licensees response to NOV 05000364,05000348/2018014-01 (EA-17-204) and determined that the reason, corrective actions taken and planned to address recurrence, and the date when full compliance will be/was achieved for this violation is adequately addressed and captured on the docket.
The licensee entered the issue into their corrective action program (CAP), CAR 267738, and conducted a root cause determination in reference to falsified plant records by SOs that went undetected by FNP personnel. Immediate corrective action included adverse employment action against the individuals involved, quarterly assessments for the next year of SO rounds, and expectation discussions with all SOs. Long term corrective actions included enhancing the operational experience program and CAP to facilitate thorough extent of condition reviews, revising licensee procedures, implementing procedural requirements across several departments to periodically and randomly audit records to determine if falsification may have occurred, and conducting an interim and final effectiveness review validating that all corrective actions have been implemented.
NOV Failure to Provide Complete and Accurate Information Related 71152B (Closed) to System Operator Rounds 05000364,05000348/2018014-02
Description:
The team reviewed the licensees response to NOV 05000364,05000348/2018014-02 (EA-17-204) and determined that the reason, corrective actions taken and planned to address recurrence, and the date when full compliance will be/was achieved for this violation is adequately addressed and captured on the docket.
The licensee entered the issue into their CAP, CAR 267738, and conducted a root cause determination in reference to falsified plant records by SOs that went undetected by FNP personnel. Immediate corrective action included adverse employment action against the individuals involved, quarterly assessments for the next year of SO rounds, and expectation discussions with all SOs. Long term corrective actions included enhancing the operational experience program and CAP to facilitate thorough extent of condition reviews, revising licensee procedures, implementing procedural requirements across several departments to periodically and randomly audit records to determine if falsification may have occurred, and conducting an interim and final effectiveness review validating that all corrective actions have been implemented.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On February 21, 2019, the inspector presented the problem identification and resolution inspection results to Dennis R. Madison and other members of the licensee staff.
DOCUMENTS REVIEWED
Procedures
FNP-0-MP-39.0, Main Steam Isolation Valve Disassembly and Reassembly, Ver. 42.0
FNP-1-STP-45.11, Miscellaneous Cold Shutdown Valves In-service Test, Ver. 32.0
FNP-1-STP-201.10, Reactor Coolant System Q1B21FT0424 Loop Calibration and Operational
Test, Ver. 40.0
FNP-1-STP-201.11, Reactor Coolant System Q1B21FT0425 Loop Calibration and Operational
Test, Ver. 37.0
FNP-1-STP-201.12, Reactor Coolant System Q1B21FT0426 Loop Calibration and Operational
Test, Ver. 33.1
FNP-1-STP-201.13, Reactor Coolant System Q1B21FT0434 Loop Calibration and Operational
Test, Ver. 35.2
FNP-1-STP-201.15, Reactor Coolant System Q1B21FT0436 Loop Calibration and Operational
Test, Ver. 34.0
FNP-1-STP-213.19, Steam Generator 1A Q1C22FT0474 Loop Calibration and Operational
Test, Ver. 62.0
FNP-1-STP-213.20, Steam Generator 1A Q1C22FT0475 Loop Calibration and Operational
Test, Ver. 67.0
FNP-1-STP-213.21, Steam Generator 1B Q1C22FT0484 Loop Calibration and Operational
Test, Ver. 62.0
FNP-1-STP-213.22, Steam Generator 1B Q1C22FT0485 Loop Calibration and Operational
Test, Ver. 64.0
FNP-1-STP-213.23, Steam Generator 1C Q1C22FT0494 Loop Calibration and Operational
Test, Ver. 63.0
FNP-1-STP-213.24, Steam Generator 1C Q1C22FT0495 Loop Calibration and Operational
Test, Ver. 66.0
FNP-1-STP-201.28, Pressurizer Power Operated Relief Valves Position Indication and Relay
Logic Contact
FNP-2-STP-201.7, Reactor Coolant System Q2B21FT0414 Loop Calibration and Operational
Test, Ver. 30.0
FNP-2-STP-201.10, Reactor Coolant System Q2B21FT0424 Loop Calibration and Operational
Test, Ver. 27.0
FNP-2-STP-201.14, Reactor Coolant System Q2B21FT0435 Loop Calibration and Operational
Test, Ver. 30.0
Verification Q1B31PCV0444B and Q1B31PCV0445A, Ver. 15.0
NMP-AD-012, Operability Determinations and Functionality Assessments, Ver. 13.3
NMP-AD-012-F01, Prompt Determination of Operability, Ver. 3.0
NMP-AD-012-F02, Formal Functionality Assessment, Ver. 2.0
NMP-AD-012-F02, Formal Functionality Assessment, Ver. 3.0
NMP-AD-012-F03, Immediate Determination of Operability (IDO) Template, Ver. 3.3
NMP-AD-012-GL01, Prompt Determination of Operability Guideline, Ver. 5.1
NMP-AD-012-GL01, Prompt Determination of Operability Guideline, Ver. 5.2
NMP-AD-012-GL02, Functionality Assessment Guideline, Ver. 5.1
NMP-AD-012-GL02, Functionality Assessment Guideline, Ver. 6.0
NMP-AD-012-GL03, Immediate Determination of Operability Guideline, Ver. 2.3
NMP-AD-012-GL03, Immediate Determination of Operability Guideline, Ver. 3.0
NMP-AD-012-GL04, Mission Times, Ver. 1.0
NMP-ES-002, System Monitoring and Health Reporting, Ver. 21.0
NMP-ES-002, System Monitoring and Health Reporting, Ver. 21.2
NMP-ES-002, System Monitoring and Health Reporting, Ver. 22.0
NMP-ES-002, System Monitoring and Health Reporting, Ver. 22.1
NMP-ES-002-001, System End User Review Process, Ver. 1.0
NMP-ES-002-001, System End User Review Process, Ver. 2.0
NMP-ES-002-002, System Peer Review Process, Ver. 3.0
NMP-ES-002-002, System Peer Review Process, Ver. 4.0
NMP-ES-002-003, System Health Reporting Instructions, Ver. 7.0
NMP-ES-002-003, System Health Reporting Instructions, Ver. 8.0
NMP-ES-002-003, System Health Reporting Instructions, Ver. 8.1
NMP-ES-002-003, System Health Reporting Instructions, Ver. 9.0
NMP-ES-002-004, System Walkdowns, Ver. 4.5
NMP-ES-002-004, System Walkdowns, Ver. 4.6
NMP-ES-002-004, System Walkdowns, Ver. 5.0
NMP-ES-002-005, System Monitoring, Ver. 8.3
NMP-ES-002-005, System Monitoring, Ver. 9.0
NMP-ES-002-006, System Vulnerability Review Process, Ver. 3.4
NMP-ES-006-002, Preventive Maintenance Change Requests, Ver. 6.0
NMP-ES-006-002, Preventive Maintenance Change Requests, Ver. 6.1
NMP-ES-006-002, Preventive Maintenance Change Requests, Ver. 6.2
NMP-ES-006-F04, Critical PM Deferral and Late PM Risk Evaluation Form, Ver. 2.0
NMP-ES-027, Maintenance Rule Program, Ver. 5.0
NMP-ES-027, Maintenance Rule Program, Ver. 6.0
NMP-ES-027, Maintenance Rule Program, Ver. 7.0
NMP-ES-027, Maintenance Rule Program, Ver. 8.0
NMP-ES-027, Maintenance Rule Program, Ver. 9.0
NMP-ES-027-001, Maintenance Rule Implementation, Ver. 8.0
NMP-ES-027-GL02, Maintenance Rule Implementation Guideline, Ver. 3.0
NMP-GM-002, Corrective Action Program, Ver. 14.4
NMP-GM-002, Corrective Action Program, Ver. 15.0
NMP-GM-002-001, Corrective Action Program Instructions, Ver. 36.1
NMP-GM-002-001, Corrective Action Program Instructions, Ver. 36.2
NMP-GM-002-001, Corrective Action Program Instructions, Ver. 37.0
NMP-GM-002-002, Effectiveness Review Instructions, Ver. 5.1
NMP-GM-002-004, CAP Training and Qualification Plan Instruction, Ver. 5.0
NMP-GM-002-004, CAP Training and Qualification Plan Instruction, Ver. 6.0
NMP-GM-002-004, CAP Training and Qualification Plan Instruction, Ver. 6.1
NMP-GM-002-F22, Equipment Reliability Checklist, Ver. 12.0
NMP-GM-002-GL03, Cause Analysis and Corrective Actions Guidelines, Ver. 28.0
NMP-GM-002-GL03, Cause Analysis and Corrective Actions Guidelines, Ver. 29.0
NMP-GM-003, Self-Assessment and Benchmark Procedure, Ver. 26.0
NMP-GM-006, Work Management, Ver. 15.0
NMP-GM-006-GL11, Work Prioritization Screening, Ver. 2.0
NMP-GM-027, Plant Health Process, Ver. 11.1
NMP-GM-027, Plant Health Process, Ver. 12.0
NMP-GM-027, Plant Health Process, Ver. 13.0
NMP-GM-027, Plant Health Process, Ver. 14.0
OS-BP-001, Operations Performance Indicators, Ver. 4.3
U611558, Instructional Manual for Main Steam Swing Disc Trip Valves - Unit 2, Ver. 3.0
U732577, Instructional Manual for Main Steam Swing Disc Trip Valves - Unit 1, Ver. 3.0
Condition Reports
10461144 10420400 10422562 10527200 10527315 10419409
10428611 10446206 10526270 10523831 10324970 10487214
10355785 10487983 10485477 10488366 10846971 10523836
10483953 10234480 10416364 10461148 10536318 10532294
10533209 10411954 10425733 10426186 10426231 10429044
10426186 10430658 10441021 10454838 10455002 10456229
10564610 10465582 10466774 10471670 10483091 10485637
10516723 10490813 10493987 10501341 10503495 10511713
10425739 10514571 10523318 10523833 10547944 10553013
10413319 10560293 10560612 10562035 10562188 10562193
10416686 10413856 10427370 10356955 10456229 10465582
10482637 10483091 10393270 10429911
Condition Reports Generated
10579299
Corrective Action Reports
2624 274668 273003 274656 274122 274642
274612 274697 273585 271468 272630 268497
271700 271755 271804 272132 272878 272464
274480 274583 275284 267738
Technical Evaluations
24232 979162 1011890 1011167 1011091 1016028
1001178 1001650 1009314 1011377 1011382 1014970
29362 1034801 986055 994651 997824 998318
Work Orders
SNC899685 SNC859023 SNC877242 SNC729314 SNC77236 SNC877236
SNC877238 SNC899479 SNC795917 SNC904016 SNC883382 SNC599020
SNC599029
Miscellaneous
PMCR 91226, Charging Pump Coupling Lubrication preventative maintenance change request
U-277513, INSTRUCTION MANUAL - CCSI PUMPS (PACIFIC PUMPS 2 1/2" RL, TYPE IJ
SAFETY PUMPS), Revision 13
ODMI-17-19, Service Water in-leakage to Unit 2 CTMT sump, Ver. 1.0
Control Room Chronological Logs, Unit 2, 6/4/18-6/8/18
Root Cause Determination Report (CAR 274480)
4160 V Project Replacement Plan
CAP Fleet Metrics December 2018
Farley Key Performance Indicators for 2018
LTAM F-14-0627, Unit 2, 4 KV Breaker Replacement Plan
LTAM F-14-0631, Unit 1, 4 KV Breaker Replacement Plan
LTAM F-17-0018, Unit 1, 4 KV Breaker Replacement Plan
LTAM F-17-0020, Unit 2, 4 KV Breaker Replacement Plan
NMP-GM-002-F08, Organizational and Programmatic (O&P) Screening Tool for CAR 274480
Maintenance Rule SSC Function Consolidation and Performance Criteria Selection Form for
System R15, 4160 Volt Switchgear, dated 10/23/18
July 2018 CDF and Flooding Initiators Spreadsheet
July 2018 LERF Spreadsheet
Root Cause Analyst Qualification Record for S. Bryson
S-ES-Maintenance Rule Qualification Record for K. Latourelle
SNC-1, Quality Assurance Topical Report, Ver. 21.0
Aggregate Impact Review Spreadsheet for 4Q2018
System R15 System Health Reports for Jan 2019
Tech Spec/TRM/Operability Determination Lesson Plan for LOCT 18-20 Segment 19-2, Ver. 1.0
Unit 1 Unit Operator Compensatory Action List