IR 05000348/2021011
| ML21347A401 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/13/2021 |
| From: | James Baptist NRC/RGN-II/DRS/EB1 |
| To: | Gayheart C Southern Nuclear Operating Co |
| References | |
| IR 2021011 | |
| Download: ML21347A401 (12) | |
Text
December 13, 2021
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT - DESIGN BASIS ASSURANCE INSPECTION (PROGRAMS) INSPECTION REPORT 05000348/2021011 AND 05000364/2021011
Dear Ms. Gayheart:
On November 16, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Joseph M. Farley Nuclear Plant and 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.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
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/
James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety
Docket Nos. 05000348 and 05000364 License Nos. NPF-2 and NPF-8
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000348 and 05000364
License Numbers:
Report Numbers:
05000348/2021011 and 05000364/2021011
Enterprise Identifier: I-2021-011-0024
Licensee:
Southern Company Nuclear
Facility:
Joseph M. Farley Nuclear Plant
Location:
Columbia, AL
Inspection Dates:
October 18, 2021 to November 05, 2021
Inspectors:
C. Baron, Contractor
P. Carman, Senior Reactor Inspector
R. Patterson, Senior Reactor Inspector
Approved By:
James B. Baptist, Chief
Engineering Branch 1
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (programs) 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
Failure to Properly Categorize MOVs 8809A & B or Check Valve Q1(2)E11V0028 in the IST Program Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000348,05000364/2021011-01 Open/Closed None (NPP)71111.21N.
The inspectors identified a Green NCV of 10 CFR 50.55a(f), Inservice Testing Requirements, subsection (4) for the licensees failure to categorize any Unit 1 & 2 RHR pump suction isolation valves (MOVs 8809A & B or check valve Q1(2)E11V0028) as inservice test (IST) Class A for which seat leakage is limited to a specific maximum amount in the closed position. Specifically, the licensees inservice testing program did not test safety-related valves in accordance with, ASME OM code Subsection ISTC-1300, Valve Categories, to ensure they could meet seat leakage requirements.
Additional Tracking Items
None.
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
71111.21N.02 - Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements POV Review (IP Section 03)
The inspectors:
a. Determined whether the sampled POVs are being tested and maintained in accordance with NRC regulations along with the licensees commitments and/or licensing bases.
Specific Guidance b. Determined whether the sampled POVs are capable of performing their design-basis functions.
c. Determined whether testing of the sampled POVs is adequate to demonstrate the capability of the POVs to perform their safety functions under design-basis conditions.
d. Evaluate maintenance activities including a walkdown of the sampled POVs (if accessible).
- (1) Q2E21MOV8108, Chemical and Volume Control System (CVCS) Charging Pump Discharge to Regenerative Heat Exchange (HX)
- (2) Q2N11PV3371A, Main Steam Line Atmospheric Vent Valve
- (3) Q2N23MOV3209A, Motor Driven Auxiliary Feedwater (MDAFW) Pump Service Water (SW) Inlet
- (4) Q1N12HV3226, Main Steam to Turbine Driven Auxiliary Feedwater Pump
- (6) Q2E11MOV8889, Residual Heat Removal (RHR) HX Discharge to Reactor Coolant System (RCS) Hot Leg
INSPECTION RESULTS
Failure to Properly Categorize MOVs 8809A & B or Check Valve Q1(2)E11V0028 in the IST Program Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Green None (NPP)71111.21N.0 Systems
NCV 05000348,05000364/2021011-01 Open/Closed The inspectors identified a Green NCV of 10 CFR 50.55a(f), Inservice Testing Requirements, subsection
- (4) for the licensees failure to categorize any Unit 1 & 2 RHR pump suction isolation valves (MOVs 8809A & B or check valve Q1(2)E11V0028) as inservice test (IST) Class A for which seat leakage is limited to a specific maximum amount in the closed position. Specifically, the licensees inservice testing program did not test safety-related valves in accordance with, ASME OM code Subsection ISTC-1300, Valve Categories, to ensure they could meet seat leakage requirements.
Description:
The inspectors noted that a refueling water storage tank (RWST) leakage inflow rate of 3.5 gallons per minute (gpm) was assumed in final safety analysis report (FSAR)
Table 15.4-14, Parameter Used in the Loss of Coolant Accident (LOCA) analysis and that the other potential leakage paths from the emergency core cooling system (ECCS) to the vented RWST included valves that were subject to leak testing. The inspectors also noted that calculation BM-98-1711-001, Reverse Flow Evaluation of RWST Check Valves, revision 2 (approved on October 24, 2001) determined that the post-accident containment pressure could be approximately 8 psid greater than the RWST static head at the time of ECCS recirculation transfer. However, this potential leakage path from the ECCS to the RWST did not include any isolation valves that were subject to leak testing to ensure that the 3.5 gpm leakage parameter assumed in the site boundary and control room radiation dose analyses would not be exceeded.
The NRC issued Information Notice (IN) 91-56, Potential Radioactive Leakage to Tank Vented to Atmosphere, alerting licensees to potential problems resulting from the leakage of isolation valves in ECCS recirculation lines to the RWST, which is vented to the atmosphere.
The NRC informed licensees of corrective actions that could address the leak path vulnerabilities, by incorporating the valves identified in the leak path into the inservice testing program and categorizing them as Category A valves. The NRC noted 10 CFR 50.55a, which references the ASME OM Code, and subsection ISTC-1300 Valve Categories stipulates that Category A valves are valves for which seat leakage is limited to a specific maximum amount in the closed position for fulfillment of their required functions. The inspectors determined the licensee did not leak test MOVs 8809A & B or check valve Q1(2)E11V0028, to assure that following a design basis accident, during ECCS recirculation, the leakage of containment sump water to the RWST is maintained within the values assumed in the calculation of site boundary and control room doses. The licensee entered the issue into their CAP as CR 10840257 on November 9, 2021.
Corrective Actions: The licensee entered the issue into their CAP as CR 10840257 on November 9, 2021. The licensee provided additional information supporting the operability and functionality of MOVs 8809A & B or check valve Q1(2)E11V0028 to prevent excessive backflow from the containment sump to the RWST. Specifically, MOVs 8809A & B are required to be closed prior to opening the associated containment sump isolation valves and check valve Q1(2)E11V0028 has been periodically tested to verify its reverse flow closure.
Performance Assessment:
Performance Deficiency: The failure of the licensee to properly categorize MOVs 8809A & B or check valve Q1(2)E11V0028 in their inservice testing program to ensure they could perform their safety function was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Specifically, the finding was a deficiency affecting the design of a mitigating SSC, and the SSC did maintain its operability and functionality.
Cross-Cutting Aspect: Not Present Performance. 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 50.55a(f), Inservice testing requirements, subsection
- (4) requires in part, that pumps and valves which are classified as ASME Class 1, Class 2, and Class 3 must meet the inservice test requirements set forth in the ASME OM Code and addenda that become effective subsequent to editions and addenda specified in paragraphs (f)(2) of this section and that are incorporated by reference in paragraph (a)(1)(iv) of this section.
Furthermore, subsection (f)(4)(ii) requires, inservice tests to verify operational readiness of pumps and valves, whose function is required for safety, conducted during successive 120-month intervals must comply with the requirements of the latest edition and addenda of the ASME OM Code incorporated by reference in paragraph (a)(1)(iv) of this section 18 months before the start of the 120-month interval. The ASME Code of record for Farley for Operation and Maintenance of Nuclear Power Plants (OM) is the 2004 Edition with Addenda through OMb-2006. Subsection ISTC-1300, Valve Categories, requires in part, that valves within this subsection shall be placed in one or more of the following categories. Category A is for valves for which the seat leakage is limited to a specific maximum amount in the closed position for fulfillment of their required function(s), as specified in ISTA-1100.
Contrary to the above, since 2001, the licensee did not categorize MOVs 8809A & B or check valve Q1(2)E11V0028 as Category A valves to ensure the ASME OM test requirements were met by leak testing the valves to ensure the dose remains within control room and site boundary limits during a design basis accident. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy. The violation was entered into the licensees CAP as CR 10840257. (NCV 05000348, 364/2021011-01 Failure to Properly Categorize MOVs 8809A & B or Check Valve Q1(2)E11V0028 in the IST Program)
Enforcement Action: This violation is being treated as a 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 November 16, 2021, the inspectors presented the design basis assurance inspection (programs) inspection results to Cheryl Gayheart and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.21N.02 Calculations
BM-98-1711-001
Reverse Flow Evaluation of RWST Check Valves
Rev. 2
71111.21N.02 Calculations
F-RIE-IEIF-
MOVR-RNK
Farley Farley Nuclear Plant Units 1 and 2 Risk Ranking for
Motor-Operated and Air-Operated Valves (Following Rev. 9
Version 3 Model update)
Version 1
71111.21N.02 Calculations
F-RIE-
VALVERISK-U00
Farley Unit 1 and 2 Valve Risk Ranking Evaluation
Version 1
71111.21N.02 Calculations
FNP-
Q1E21MOV8803B
Thrust and Torque Calculation
Rev. 2
71111.21N.02 Calculations
FNP-
Q1N23MOV3209A
Thrust and Torque Calculation
Rev. 2
71111.21N.02 Calculations
FNP-
Q2E11MOV8887A
Thrust and Torque Calculation
Rev. 1
71111.21N.02 Calculations
FNP-
Q2E11MOV8889
Thrust and Torque Calculation
Rev. 1
71111.21N.02 Calculations
SE-91-1925-14-
MOV 3232A,B,C: Terminal Voltage at End of Stroke
Rev. 1
71111.21N.02 Calculations
SE-94-0-0378-001
MOV Combination Starter Component Sizes and Settings
Rev. 5
71111.21N.02 Calculations
SE-94-0470-001
Unit 1 As-Built Load Study
Rev. 10
71111.21N.02 Calculations
SE-SNC529029-
001
Unit 1 Minimum Expected Voltage Study
Rev. 2
71111.21N.02 Calculations
SM-04-4801-002
AOV Design Basis Review - Setpoints for Q1N12HV3226
Version 2.0
71111.21N.02 Calculations
SM-90-1653-001
MOV Thrust Requirements for Gate & Globe Valves
Version 17
71111.21N.02 Calculations
SM-90-1653-002
Reduced Voltage Torque/Thrust Capability for Gate &
Globe Valves in the FNP MOV Program
Version 23
71111.21N.02 Calculations
SM-90-1653-002
Reduced Voltage Torque/Thrust Capability for Gate &
Globe Valves in the FNP MOV Program
Rev. 23
71111.21N.02 Calculations
SM-90-1653-003
Design Basis Differential Pressure for the MOV Program
Rev. 15
71111.21N.02 Calculations
SM-90-1653-003
Design Basis Differential Pressure for the MOV Program
Version 15
71111.21N.02 Calculations
SM-99-2189-007
AOV Design Basis Review - Setpoints for
Q2N11PV3371A/B/C
Version 2
71111.21N.02 Corrective Action
Documents
10835846
Discrepancy Between the Values for Required Voltage for
MOV8803B
10/20/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Resulting from
Inspection
71111.21N.02 Corrective Action
Documents
Resulting from
Inspection
10837853
Revision Requested for NMP-ES-017-008
10/29/2021
71111.21N.02 Corrective Action
Documents
Resulting from
Inspection
10840257
Maximum Allowable Leakage from the Containment Sump
to RWST
11/09/2021
71111.21N.02 Corrective Action
Documents
Resulting from
Inspection
10840275
Incorrect Test Methodology for Category A/C Check Valves 11/09/2021
71111.21N.02 Corrective Action
Documents
Resulting from
Inspection
CR 10835850
10835850 - Discrepancy in the Electrical Inspection
Procedure
10/20/2021
71111.21N.02 Drawings
D-175033
Main Steam and Auxiliary Steam Systems
Version 12
71111.21N.02 Drawings
D-175038
Sht. 1, P&ID - Safety Injection System
Rev. 44
71111.21N.02 Drawings
D-205007
P&ID - Auxiliary Feedwater System, Sheet 1
Version 29.0
71111.21N.02 Drawings
D-205033
P&ID - Main Steam and Auxiliary Steam System, Sheet 1
Version 43.0
71111.21N.02 Drawings
D-205038
Sht. 1, P&ID - Safety Injection System
Rev. 39.0
71111.21N.02 Drawings
D-205038
Sht. 2, P&ID - Safety Injection System
Rev. 24.0
71111.21N.02 Drawings
D-205039
P&ID Chemical and Volume Control System, Sheet 6
Version 11.0
71111.21N.02 Drawings
Outline & Dimensions for HV-3226
Version 2.0
71111.21N.02 Drawings
150# OSY Gate Valve
11/25/1975
71111.21N.02 Drawings
Atmosphere Relief Valve
Version 13.0
71111.21N.02 Drawings
1500# Bolted Bonnet Gate Valve Q2E21MOV8106,
Q2E21MOV8107, & Q2E21MOV8108 (V265, V257, &
V258)
Version 1.0
71111.21N.02 Miscellaneous
ALA-10-147
Summary of Seismic and Weak Link Calculation Performed
for Valves at Locations 8106, 8107 and 8108
11/18/2020
71111.21N.02 Miscellaneous
ALA-11-89
Increase of Weak Link Closing Trust for Farley Units 1 and
10/27/2011
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Valve Locations 8106, 8107, and 8108
71111.21N.02 Miscellaneous
LDCR 20-044
Removal of Containment Penetrations 23, 24, 28, 42, 43,
44, 45, 46, 61a, 61b, 66 and 67 from the Requirements of
Technical Specification 5.5.17, Containment Leakage Test
Program
Version 1.0
71111.21N.02 Procedures
FNP-1-EEP-1
Loss of Reactor or Secondary Coolant
Rev. 35.0
71111.21N.02 Procedures
FNP-1-ESP-1.2
Post LOCA Cooldown and Depressurization
Rev. 26.0
71111.21N.02 Procedures
FNP-1-ESP-1.3
Transfer to Cold Leg Recirculation
Rev. 25.0
71111.21N.02 Procedures
FNP-1-ESP-1.4
Transfer to Simultaneous Cold and Hot Leg Recirculation
Rev. 16.0
71111.21N.02 Procedures
FNP-1-SOP-7.0
Residual Heat Removal System
Rev. 112.0
71111.21N.02 Procedures
FNP-1-STP-11.17
RHR RWST Suction Check Valve Reverse Closure Test
10/09/19
71111.21N.02 Procedures
FNP-1-STP-21.3
TDAFWP Steam Supply Valve IST
06/28/2021
71111.21N.02 Procedures
FNP-1-STP-4.10
Reverse Flow Testing of RWST to Charging Pump Check
Valve & CVCS Emerg. Borate Filter to Chg. Pmp. Suction
Rev. 22.0
71111.21N.02 Procedures
FNP-1-STP-40.0B
Safety Injection with Loss of Off-Site Power Test - B Train
Rev. 12.0
71111.21N.02 Procedures
FNP-1-STP-45.4
ECCS Refueling Outage Valves Inservice Test
04/09/21
71111.21N.02 Procedures
FNP-1-UOP-1.1
Startup of Unit from Cold Shutdown to Hot Standby
Rev. 110.2
71111.21N.02 Procedures
FNP-1-UOP-1.2
Startup of Unit from Hot Standby to Minimum Load
Rev. 120.0
71111.21N.02 Procedures
FNP-2-SOP-7.0
Residual Heat Removal System
Rev. 102.0
71111.21N.02 Procedures
FNP-2-STP-11.17
RHR RWST Suction Check Valve Reverse Closure Test
10/23/20
71111.21N.02 Procedures
FNP-2-STP-11.6
Residual Heat Removal Valves Inservice Test
11/02/20
71111.21N.02 Procedures
FNP-2-STP-11.6
Residual Heat Removal Valves Inservice Test
07/26/21
71111.21N.02 Procedures
FNP-2-STP-158.0
Reactor Coolant System Pressure Isolation Valve Leak
Test
11/10/20
71111.21N.02 Procedures
FPN-0-SOP-103.0
Return to Service Checklist and Return to Service Systems
Lineup
Rev. 49.0
71111.21N.02 Procedures
NMP-ES-017
Motor-Operated Valve Program
Version 10.1
71111.21N.02 Procedures
NMP-ES-017-001
Motor Operated Valve (MOV) Regulatory Scoping Process
Version 6.2
71111.21N.02 Procedures
NMP-ES-017-001-
F-V3
FNP GL89-10/96-05 MOV Program Scope
Version 1.0
71111.21N.02 Procedures
NMP-ES-017-002
Motor Operated Valve Design Basis Setpoint Deamination
Version 6.2
71111.21N.02 Procedures
NMP-ES-017-003
Motor Operated Valve Performance Trending and Margin
Version 5.2
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Management
71111.21N.02 Work Orders
SNC75202,
SNC390935,
SNC679107,
SNC681216,
SNC681217,
SNC831498,
SNC835825,
SNC835825,
SNC975098