IR 05000348/2020001
| ML20126G238 | |
| Person / Time | |
|---|---|
| Site: | Farley, 07200042  |
| Issue date: | 05/05/2020 |
| From: | Alan Blamey NRC/RGN-II/DRP/RPB2 |
| To: | Gayheart C Southern Nuclear Operating Co |
| References | |
| IR 2020001 | |
| Download: ML20126G238 (13) | |
Text
May 5, 2020
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000348/2020001 AND 05000364/2020001 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION REPORT 07200042/2020001
Dear Ms. Gayheart:
On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Joseph M. Farley Nuclear Plant. On April 21, 2020, the NRC inspectors discussed the results of this inspection with Mr. Delson Erb and other members of your staff. The results of this inspection are documented in the enclosed report.
One Severity Level IV violation without an associated finding is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
No NRC-identified or self-revealing findings were identified during this inspection.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Joseph M. 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 Title 10 of the Code of Federal Regulations 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 and 07200042 License Nos. NPF-2 and NPF-8
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000348 and 05000364 and 07200042
License Numbers:
Report Numbers:
05000348/2020001 and 05000364/2020001 and 07200042/2020001
Enterprise Identifier: I-2020-001-0061and I-2020-001-0086
Licensee:
Southern Nuclear Operating Co., Inc.
Facility:
Joseph M. Farley Nuclear Plant
Location:
Columbia, AL
Inspection Dates:
January 01, 2020 to March 31, 2020
Inspectors:
P. Meier, Senior Resident Inspector
K. Miller, Resident Inspector
Approved By:
Alan J. Blamey, Chief
Reactor Projects Branch 2
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at Joseph M. Farley Nuclear Plant, in
accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs
program for overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Pressurizer Safety Valve Lift Pressure Outside of Technical Specifications Limits due to
Setpoint Drift
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Not Applicable
Closed
Not Applicable
A self-revealed Severity Level (SL) IV NCV of Technical Specifications (T.S.) 3.4.10,
Pressurizer Safety Valves, was identified when a routine lift pressure test revealed that the
'A' pressurizer safety valve (Q1B13V0031A) as-found set pressure was lower than allowed by
T.S. Surveillance Requirement 3.4.10.1 for a duration that exceeded the conditions T.S.
required action completion time.
Additional Tracking Items
Type
Issue Number
Title
Report Section
Status
LER
(Licens
ee
Event
Report)
05000348/2019-001-00
LER 2019-001-00
Pressurizer Safety Valve Lift
Pressure Outside of
Technical Specifications
Limits due to Setpoint Drift
Closed
PLANT STATUS
Unit 1 began the report period at approximately 100 percent rated thermal power (RTP) and
remained at or near 100 percent RTP through the end of the report period.
Unit 2 began the report period at approximately 100 percent RTP and remained at or near 100
percent RTP through the end of the report 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 performed plant status activities described in
IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem
Identification and Resolution. 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
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1)
Unit 1 'A' containment spray system while the 'B' train was inoperable for testing on
January 2, 2020 (FNP-1-SOP-9.0A).
(2)
- 1 diesel driven fire pump and the motor driven fire pump alignment during
maintenance on the #2 diesel driven fire pump on January 15, 2020 (drawing
D170366).
(3)
Unit 2 'B' train high head safety injection system with the 'A' train high head safety
injection out of service for planned maintenance on March 9, 2020 (FNP-2-SOP-
8.1A).
(4)
Unit 2 turbine driven auxiliary feedwater pump and 'B' motor driven
auxiliary feedwater pump during a planned 'A' motor driven auxiliary feedwater pump
maintenance outage on March 16, 2020 (FNP-2-SOP-22.0A).
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a
walkdown and performing a review to verify program compliance, equipment functionality,
material condition, and operational readiness of the following fire areas:
(1)
Fire zone 202 (unit 1 communication room) in March 2020.
(2)
Fire zone 235 (unit 1 switchgear / control rod drive mechanism room) in March 2020.
(3)
Fire zone 2202 (unit 2 communication room) in March 2020.
(4)
Fire zone 2235 (unit 2 switchgear / control rod drive mechanism room) in March 2020.
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
(1)
Unit 1 auxiliary building, 100-foot elevation, in the auxiliary feed water pump area on
February 20 - 27, 2020 (calculation BM-99-1932-001).
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1
Sample)
(1)
The inspectors observed and evaluated licensed operator performance in the Control
Room during unit 1 solid state protection system and reactor trip breaker testing on
March 6, 2020. On March 30, 2020, observed the unit 1 conduct of operations
involving alarm response, reactivity control, and transfer of diesel fuel between
emergency diesel generator fuel oil storage tanks. On March 31, 2020, observed
performance of a turbine driven auxiliary feedwater pump surveillance and reactivity
control.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1)
The inspectors observed and evaluated license operator continuing training simulator
scenario 20-2, as left on February 26, 2020. The scenario involved a faulted and
ruptured steam generator.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components (SSCs) remain capable of performing their intended
function:
(1)
Unit 1 'C' charging pump welding repairs from January 7-15, 2020 (SNC1069334;
SNC1070049).
(2)
Unit 2 'A' component cooling water pump bearing issue discovered on February 13,
2020 (Condition Report (CR) 10687227).
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the
following planned and emergent work activities to ensure configuration changes and
appropriate work controls were addressed;
(1)
Unit 1 'C' charging pump out of service for unplanned maintenance on January 7-10,
2020 (SNC1069334).
(2)
Unit 1 '1D' 600-volt load center outage affecting the operability of the 1-2A emergency
diesel generator for unit 1 on January 22, 2020 (Work Order (WO) SNC632876).
(3)
Unit 2 'B' containment spray cooler outage and planned risk informed completion time
contingency from March 2 - 5, 2020 (WO SNC1028105).
(4)
Unit 1 'A' motor driven auxiliary feedwater pump testing, 1-2A emergency diesel
generator 24-hour surveillance, 1F 600 volts motor control center maintenance
outage affecting control ventilation / filtration, and utility pole work potentially affecting
the 12kv supply to the circulating water fans on March 12, 2020 (W/O SNC1078077 &
SNC959868).
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1)
Unit 1 'C' charging pump balancing line leak identified on January 7, 2020 (CR
10676102).
(2)
Unit 2 turbine driven auxiliary feedwater pump to the unit 2 'B' steam generator supply
valve (2N23HV3228B) slow stroke time identified on December 31, 2019 (CR
10674598).
(3)
Unit 1 hot leg thermal stratification resistance temperature detector issue identified on
January 27, 2020 (CR10681581).
(4)
Unit 1 turbine driven auxiliary feedwater pump steam supply drain pot not
automatically blowing down identified on February 23, 2020 (CR 10689705).
(5)
Transformer supply to the Unit 1 '1S' 600-volt motor control center thermal issue
(affecting the 1-2A emergency diesel generator operability) identified on March 9,
2020 (CR10694270).
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1
Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1)
Start-up transformer sudden pressure relay modification to remove the trip function
(design change package SNC1065251).
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)
The inspectors evaluated the following post maintenance test activities to verify system
operability and functionality:
(1)
Unit 1 'C' charging pump balancing line leak repair on January 7-10, 2020 (CR
10676102; WO SNC1069334).
(2)
- 2 diesel driven fire pump 18 month scheduled maintenance during the week of
January 14, 2020 (WO SNC983818).
(3)
Troubleshooting and repair of the unit 2 1-2A emergency diesel generator output
breaker control room indicating lights on January 22 - 23, 2020 (WO SNC1043454).
(4)
Removal and replacement of a unit 1 containment tendon (H-13BC) field end anchor
head on January 29 - 30, 2020 (WO SNC1020168).
(5)
Unit 2 'A' component cooling water pump bearing replacement from February 14 - 17,
2020 (CR 10687227; WO SNC1075744).
(6)
Control room a/c system maintenance outage from March 2 - 4, 2020 (WO
SNC889323).
(7)
Unit 2 turbine driven auxiliary feedwater pump remote shutdown panel switch
replacement on March 10-12, 2029 (SNC1083141).
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01) (4 Samples)
(1)
Unit 2 'B' train reactor trip breaker and solid state protection system testing on
January 7, 2020 (FNP-2-STP-33.0B, FNP-2-STP-33.2B).
(2)
Unit 1 'B' charging pump surveillance test on January 27, 2020 (FNP-1-STP-4.2).
(3)
Unit 1 'B' emergency diesel generator load rejection test and 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> loaded run
surveillance on January 29, 2020 (FNP-1-STP-80.8).
(4)
Unit 1 containment purge exhaust containment piping penetration local leak rate test
on February 7, 2020 (SNC1036119).
Inservice Testing (IP Section 03.01) (1 Sample)
(1)
Unit 1 turbine driven auxiliary feedwater pump quarterly inservice testing on January
8, 2020 (FNP-2-STP-22.16).
FLEX Testing (IP Section 03.02) (1 Sample)
(1)
FLEX preventive maintenance testing for diesel generators and diesel driven pumps
performed on February 4, 2020 (WO SNC988106; WO SNC988424).
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
(1)
Observed a crew in the control room simulator respond to an event for training
purposes where an emergency declaration and notification was required due to a
steam generator tube rupture and represented a drill and exercise
performance opportunity on February 26, 2020.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (2 Samples)
(1)
Unit 1 (January 1, 2019 - December 31, 2019).
(2)
Unit 2 (January 1, 2019 - December 31, 2019).
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2
Samples)
(1)
Unit 1 (January 1, 2019 - December 31, 2019).
(2)
Unit 2 (January 1, 2019 - December 31, 2019).
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)
(1)
Unit 1 (January 1, 2019 - December 31, 2019).
(2)
Unit 2 (January 1, 2019 - December 31, 2019).
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
(1)
The inspectors reviewed the licensees corrective action program for potential
adverse trends in fire detection issues (CR 10683777; CR 10629791) that might be
indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1)
Resolution of equipment issues tracked on the operable but degraded / non-
conforming list from February 18, 2020 (NMP-AD-012).
71153 - Followup of Events and Notices of Enforcement Discretion
Event Report (IP Section 03.02) (1 Sample)
The inspectors evaluated the following licensee event reports (LERs):
(1)
LER 05000348/2019-001-00, Pressurizer Safety Valve Lift Pressure Outside of
Technical Specifications Limits due to Setpoint Drift (ADAMS Accession No.
ML19343B093). The inspection conclusions associated with this LER are
documented in this report under Inspection Results Section 71153.
OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants
Operation of an Independent Spent Fuel Storage Installation at Operating Plants (1 Sample)
(1)
The inspectors evaluated the licensees independent spent fuel storage installation
cask loadings on March 9 - 27, 2020. Specifically, the inspectors observed the
following activities;
Fuel selection and fuel loading
Heavy load movement of transfer cask
Drying and backfill evolutions
Transfer and transport evolutions
Radiological field surveys.
INSPECTION RESULTS
Observation: Main Control Room Fire Alarms
The inspectors reviewed the licensees corrective action program for trends that might be
indicative of a more significant safety issue. The inspectors focused their review on unit 1 and
unit 2 main control board fire alarm windows where it remained continuously lit or in re-flash
due to apparent nuisance alarms or issues that would not reset. Many of these were
associated with fire detection and suppression systems in risk significant areas of the plant
that require the dispatch of an operator to a fire alarm panel to identify the fire zone causing
the alarm. The inspectors review nominally considered the 6-month period beginning in July
2019 through January 2020, although some examples extended beyond those dates when
the scope of the trend warranted. The inspectors compared their results with the licensees
analysis of trends. Additionally, the inspectors reviewed the adequacy of corrective actions
associated with a sample of the issues identified in the licensees trend reports. The
inspectors also reviewed corrective action documents that were processed by the licensee to
identify potential adverse trends in the condition of fire protection structures, systems, and / or
components as evidenced by acceptance of long-standing non-conforming or degraded
conditions. The inspectors determined that the licensee was following approved
administrative controls for the alarms and implementing long-term corrective action plans to
resolve the causes. The inspectors will continue to assess implementation of the licensees
action plan and verify that their actions trend in a positive direction.
Pressurizer Safety Valve Lift Pressure Outside of Technical Specifications Limits due to
Setpoint Drift
Cornerstone
Severity
Cross-Cutting
Aspect
Report
Section
Not
Applicable
Closed
Not
Applicable
A self-revealed Severity Level (SL) IV NCV of Technical Specifications (T.S.) 3.4.10,
Pressurizer Safety Valves, was identified when a routine lift pressure test revealed that the
'A' pressurizer safety valve (Q1B13V0031A) as-found set pressure was lower than allowed by
T.S. Surveillance Requirement 3.4.10.1 for a duration that exceeded the conditions T.S.
required action completion time.
Description: During the Farley Nuclear Plant unit 1 October 2019 refueling outage,
pressurizer safety valve Q1B13V0031A was removed from service and sent to an off-site
testing facility. On October 11, 2019, the site was notified that during testing on October 10,
2019 the as-found set pressure was at 2444 psig, which was low outside the plant T.S.
allowable lift pressure setting range of 2460 psig to 2510 psig. The valve had been installed
and placed in service at Farley Nuclear Plant unit 1 during the 2016 fall outage and remained
in service during three complete 18-month fuel cycles. Pressurizer safety valve
Q1B13V0031A from Unit 1 was replaced with a similar operable refurbished valve during the
October 2019 refueling outage. Licensee Event Report (LER) 05000348/2019-001-00,
Pressurizer Safety Valve Lift Pressure Outside of Technical Specification Limits due to
Setpoint Drift, was submitted by the licensee for this event.
Corrective Actions: The valve was replaced with a similar operable refurbished valve during
the refueling outage prior to plant startup.
Corrective Action References: CR 10654744
Performance Assessment: The NRC determined this violation was not reasonably
foreseeable and preventable by the licensee and therefore is not a performance deficiency.
Specifically, random setpoint drift is a recognized valid phenomenon that can occur despite
routine testing and maintenance.
Enforcement:
Severity: Traditional Enforcement is being used to disposition this violation with no
associated Reactor Oversight Process performance deficiency per section 3.10 of the
Enforcement Manual. The inspector assessed the severity of the violation using Section 6.1
of the Enforcement Policy and determined the significance is appropriately characterized as
Severity Level IV, due to the inappreciable potential safety consequences. 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 Final Safety Analysis Report, based on the as-found condition.
Violation: Farley Nuclear Plant unit 1 T.S. LCO 3.4.10, Pressurizer Safety Valves, requires
three operable pressurizer safety valves with lift settings between 2460 psig and 2510 psig,
while the Unit is in modes 1, 2, and 3. With one pressurizer safety valve inoperable, Action
Statement, Condition A. Required Action A.1, requires 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, requires that the unit be in mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Contrary
to the above, the licensee determined the pressurizer safety valve setting was outside the
T.S. limits longer than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 15 minutes during the last three operating cycles, between
November 2016 and October 1, 2019, while the Unit was in modes 1 and 2.
Enforcement Action: This violation is being treated as an non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On April 21, 2020, the inspectors presented the integrated inspection results to Mr. Delson Erb
and other members of the licensee staff.