IR 05000348/2021012

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Triennial Fire Protection Team Inspection (FPTI) Report 05000348/2021012 and 05000364/2021012
ML21203A001
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 07/19/2021
From: Scott Shaeffer
Division of Reactor Safety II
To: Kharrl C
Southern Nuclear Operating Co
References
IR 2021012
Download: ML21203A001 (13)


Text

July 19, 2021

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT - TRIENNIAL FIRE PROTECTION TEAM INSPECTION (FPTI) REPORT 05000348/2021012 AND 05000364/2021012

Dear Mr. Kharrl:

On July 1, 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 Robert Norris and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Scott M. Shaeffer, Chief Engineering Branch 2 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: NPF-2 and NPF-8 Report Numbers: 05000348/2021012 and 05000364/2021012 Enterprise Identifier: I-2021-012-0007 Licensee: Southern Nuclear Operating Co., Inc.

Facility: Joseph M. Farley Nuclear Plant Location: Columbia, AL Inspection Dates: June 14, 2021 to July 02, 2021 Inspectors: J. Dymek, Reactor Inspector W. Monk, Senior Reactor Inspector (Team Lead)

J. Montgomery, Senior Reactor Inspector D. Strickland, Reactor Inspector Approved By: Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial fire protection team inspection at Joseph M. Farley Nuclear Plant, in accordance with the Reactor Oversight Process (ROP). 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

No findings or violations of more than minor significance were identified.

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 industry standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin tele-work. In addition, regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

REACTOR SAFETY

71111.21N.05 - Fire Protection Team Inspection (FPTI) Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)

The inspectors verified that components and systems will function as required to support the credited functions stated for each sample. Additional inspection considerations were located in the fire hazards analysis (FHA) or nuclear safety capability assessment (NSCA).

(1) SSC #1 (Fire Prevention) - Combustible Controls and Hot Work Administrative Programs
(2) SSC #2 (Detection/Suppression) - Deluge Fixed Spray Water Suppression Systems (Switchyard and Turbine Building)
(3) SSC #3 (SSD) - Comprehensive Non-Power Operations Review of the RHR System
(4) SSC #4 (SSD) - Comprehensive Safe and Stable Condition Review of the CCW System a. Review deficiencies or open fire protection impairments for the selected system, including any temporary modifications, operator workarounds, or compensatory measures.

b. Verify that operator actions can be accomplished as assumed in the licensees FHA, or as assumed in the licensees fire probabilistic risk assessment (FPRA)analysis and SSA.

c. Review repetitive or similar maintenance work requests which could be an indicator of a design deficiency and could affect the ability of the components to perform their functions, when needed.

d. Ensure that post maintenance and/or surveillance activities are performed as scheduled.

e. Perform a walkdown inspection to identify equipment alignment discrepancies.

Inspect for deficient conditions such as corrosion, missing fasteners, cracks, and degraded insulation.

f. Ensure the selected SSCs that are subject to aging management review (AMR)pursuant to 10 CFR Part 54 are being managed for aging (e.g., loss of material, cracking, reduction of heat transfer) in accordance with appropriate aging management programs. Verify that the licensees aging management program activities (such as, Fuel Oil Analysis or Selective Leaching Aging Management Program) associated with FP equipment are being implemented.

g. If a review of operating experience issues will be completed for the selected inspection sample, verify that the licensee adequately reviewed and dispositioned the operating experience in accordance with their processes.

Fire Protection Program Administrative Controls (IP Section 03.02) (2 Samples)

The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis (CLB). If applicable, ensure that the licensees FPP contains adequate procedures to implement the selected administrative control. Verify that the selected administrative control meets the requirements of all committed industry standards.

(1) Fire Protection Administrative Program #1 - NFPA 805 Monitoring Program
(2) Fire Protection Administrative Program #2 - Fire Brigade Drills and Training

Fire Protection Program Changes/Modifications (IP Section 03.03) (2 Samples)

The inspectors verified the following:

a. Changes to the approved FPP do not constitute an adverse effect on the ability to safely shutdown.

b. The adequacy of the design modification, if applicable.

c. Assumptions and performance capability stated in the SSA have not been degraded through changes or modifications.

d. The FPP documents, such as the Updated Final Safety Analysis Report, fire protection report, FHA, and SSA were updated consistent with the FPP or design change.

e. Post-fire SSD operating procedures, such as abnormal operating procedures, affected by the modification were updated.

(1) FPP Changes / Modification #1 - Design Change Package (DCPs) SNC 1054443/1054444/1054445/1054446 Unit 2 AUX & Turbine Building Class B Fire Protection Modifications
(2) FPP Changes / Modification #2 - DCP SNC 968080 Fire Protection Change Evaluation for DECP Install Line Stops on the Fire Pump Discharge Lines

INSPECTION RESULTS

No findings of more than minor significance were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained nor documented in this report.

  • On July 1, 2021, the inspectors presented the Fire Protection Team Inspection (FPTI)results to Robert Norris, Plant Manager and other members of the licensee staff during the Exit Meeting.

THIRD PARTY REVIEWS Inspectors reviewed ATC-Combustion Engineering Solutions Investigation of the Failure of a Section of Fire Protection Piping at Farley Nuclear Plant during the inspection period. No other third-party documentation was reviewed during the inspection.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.21N.05 Calculations 2380-1102-PGK-01 Evaluation of MOV Pressure Boundaries for IN 92- 0

Hot-Short Events

SE-C051326701 Farley Nuclear Power Plant Units 1 and 2 NFPA 06/09/2020

805 Non-Power Operations

SE-C051326701-003 FNP NSEL and Safe and Stable Fault Trees 06/09/2020

SE-C051326701-011 FNP Recovery Action Feasibility Evaluation 07/27/2012

SE-C051326701-012 NFPA 805 Defense in Depth (DID) Recovery 09/05/2012

Actions Credited in Calculation SE-C051326701-

008

Corrective Action CAR 266711 Attach manufacturer documentation with regards to 09/15/2016

Documents 3-hour fire door rating

Corrective Action CR 10805916 2T-12A SGFP Deluge Nozzles Partially Blocked by 06/15/2021

Documents Installed Tarp/Catch Bag

Resulting from CR 10806250 System 2A-27 Indicating Light Non-Functional 06/16/2021

Inspection CR 10806253 Fire Brigade Ready Room Trash Can with Self- 06/16/2021

Extinguishing Lid was Full

CR 10806280 Lumber on U2 Turbine Deck with No Transient 06/16/2021

Combustible Permit

CR 10806305 FNP-1-AOP-28.1 Attachment 9 has Numbering and 06/16/2021

Formatting Issues with Response Obtained and

RNO Steps

CR 10806350 Procedure Enhancement Suggestions - Hot Work 06/16/2021

Procedure

CR 10806359 Unsecured Ladder Found in Turbine Building 06/16/2021

(Personal Safety)

CR 10806366 Pressure Indicator Gauge Broken on Motor Driven 06/16/2021

Fire Pump

CR 10806369 #2 Fire Water Storage Tank Level Control Valve 06/16/2021

Cycling

CR 10806591 U2 TB Battery RM Louver Found Closed (H2 B/U 06/17/2021

Concern)

CR 10806623 Corrosion Found on Pre-action Header in the U2 06/17/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

CCW Room

CR 10806654 U2 Turbine Building Damper out of Normal Position 06/17/2021

CR 10806685 Fire Extinguishers in Equipment Room 115 06/17/2021

CR 10807352 NRC Inspection Lessons Learned - Walkdowns / 06/21/2021

Assessments

CR 10809299 AOP-28.1 Version Update Needed 06/29/2021

CR 10809409 Light Out on Cardox Panel 06/29/2021

CR 10809789 Unsecured Nitrogen Dewars Found on U1 155 06/30/2021

CR 10809791 Evaluate and revise FNP-ACP-35.3 Attachment 2 06/30/2021

CR 10809794 (NRC Identified) Sound Powered Phone Jacks 06/30/2021

Degraded

CR 10809936 DDFP Overspeed Test Enhancement 07/01/2021

Drawings D 170347 Farley NPP Unit 1 Fire Protection Piping-Auxiliary Revision 16

Building Below El. 121'.

D-200184 P&ID Fire Protection Main Transformers & Valve 12/29/1978

House

D-205002 P&ID for Component Cooling Water System 31.0

D170345 Fire Protection Piping Diesel Engine Driven Pumps Revision 1

Fuel & Exhaust Piping

D170366 Fire Protection P & ID Pump House & Yard Mains Version 1.0

D200-201 Sheet #1 Joseph M. Farley Nuclear Plant Unit #2 Cooling Version 5.0

Tower Layout

D200-201 Sheet #2 Joseph M. Farley Nuclear Plant Cooling Tower Version 1.0

Layout

D205041 P&ID for Residual Heat Removal System 20.0

U160130 Fire Protection-Fuel System for Diesel Driven Fire Revision 2

Pumps

U162363 Fire Protection-Sprinkler System for Main Power Version 1.0

Transformer 1TR66

U262255 Fan Data-Turbine Building Battery room 12/29/1975

Engineering SNC 1054445 U2 Auxiliary & Turbine Building Class B Fire Revision 0

Changes Protection Modifications

SNC 1054444 U2 Auxiliary & Turbine Building Class B Fire Revision 0

Protection Modifications

Inspection Type Designation Description or Title Revision or

Procedure Date

SNC 1054446 U2 Auxiliary & Turbine Building Class B Fire Revision 0

Protection Modifications

SNC-1150857 1B RCP Seal Leak-Off Line Modification 4/6/2021

SNC471156 NFPA 805: IN 92-18 U1 MOV Hot Short Failure 03/19/2015

MOD

SNC471157 NFPA 805: IN 92-18 U2 MOV Hot Short Failure 11/06/2014

MOD

Engineering CAR 278955LOE Cause Determination Report Summary - Fire Revision 1

Evaluations Protection Main Rupture

DCP SNC1054443 Unit 2 AUX & TB Class B Fire Protection 08/06/2020

Modifications

SNC 1151384 Reactor Make-Up Water Storage Tank (RMWST) 4/30/2021

Cover Replacement

SNC 1154174 Modification for Leading Edge Flow Meter (LEFM) 4/30/2021

Transmitters

TE 1051647 Technical Evaluation-Focused Area Self 10/5/2020

Assessment-Fire Protection

Miscellaneous A-181805 NFPA Fire Protection Program Design Basis Version 8.0

Document-Joseph M. Farley Nuclear Plant

EPRI Update Non-Suppression Curves 2015

30020222936/NUREG2169

F-021-2020 Fire Drill Package-Unit #1 Turbine Building 3/05/2020

Elevation 137'

F-022-2020 Fire Drill Package-Service Building Annex 3/12/2020

F-2021-03 Fire Drill Package Unit #1 NRSAB Room 191/192 2/19/2021

GN 500 Detail Specification for Fire Protection System 05/03/1971

Section System 1 Header and Riser System

NEIL Nuclear Electric Insurance Limited-Joseph M. 9/12/2019

Farley Nuclear Plant Boiler and Machinery and

Property Loss Control Evaluation

NFPA 10-1973 PORTABLE FIRE EXTINGUISHERS Code of

Record

1973

NFPA 20-1974 Installation of Centrifugal Fire Pumps Code of

Inspection Type Designation Description or Title Revision or

Procedure Date

Record

1974

NFPA 80-1973 Fire Doors and Fire Windows Code of

Record

1973

S-FP-115 NFP-SNC-Course Completion Record Table Top 6/25/2020

Simulation Fire Drill

SM-C051326701-016 Master Scoping List Equipment Type-Extinguisher

Procedures FNP--AOP-29.0 AOP for Plant Fire 53.0

FNP-0-ACP-35.3 ADMINISTRATIVE CONTROL OF TOOLS AND Version 7.0

EQUIPMENT LEFT UNATTENDED IN THE PLANT

FNP-0-EIP-16.0-F22 Checklist X Hot Shutdown Panels, Unit 1 (EP) 04/16/2021

FNP-0-EIP-16.0-F22 Checklist X Hot Shutdown Panels, Unit 1 (EP) 01/13/2021

FNP-0-EIP-16.0-F23 Checklist Y Hot Shutdown Panels, Unit 2 (EP) 04/16/2021

FNP-0-EIP16.0-F23 Checklist Y Hot Shutdown Panels, Unit 2 (EP) 01/13/2021

FNP-0-FSP 201.2 Diesel Driven Fire Pump #2 Functional Test Version 20

FNP-0-FSP-201.1 Diesel Driven Fire Pump #1 Functional Test Version 22

FNP-0-FSP-201.1 No. 1 Diesel Driven Fire Pump Functionality Test Version 23.0

FNP-0-FSP-201.3 Motor Driven Fire Pump Functional Test Version 12

FNP-0-FSP-35.0 Portable Extinguisher Monthly Inspection Version 45.7

FNP-0-FSP-400.0 Diesel Driven Fire Pump Inspection Version 16.1

FNP-0-FSP-44.0 Inspection of AFFF Version 5.1

FNP-0-FSP-62.0 Analysis of "A" Fire Diesel Fuel Storage Tank Version 10.1

Contents

FNP-0-FSP-62.1 Fire Diesel Fuel Oil Bottom Sample Quality Version 4.1

Appearance Test

FNP-0-GMP-100.0 Catch Bag Control Program VERSION

6.1

FNP-0-SOP-0.4 Fire Protection Program Administration and FP 121.0

LCO Requirements

FNP-0-SOP-61.0 Fire Protection-Pump House and Yard Main Version 49.3

FNP-0-UOP-4.0 General Outage Operations Guidance 64

FNP-1-AOP-28.1 Farley Nuclear Plant AOP 28.1 39.0

Inspection Type Designation Description or Title Revision or

Procedure Date

FNP-1-AOP-28.2 AOP for Fire in The Control Room 31.2

FNP-1-ESP-1.1 SI Termination Operating Procedure 27.1

FNP-1-FSP-39.1 Portable CO2 Fire Extinguishers-Annual Version 4.0

Conductivity Test

FNP-1-FSP-9.0 Portable Extinguishers - Monthly VERSION

44.4

FNP-2-FPP-2.0 UNIT 2 TURBINE BUILDING PRE-FIRE PLAN VERSION

2.0

FNP-2-FSP-39.2 Portable CO2 Fire Extinguisher-Annual Conductivity Version 4.0

Test

FNP-2-FSP-9.0 Portable Fie Extinguishers-Monthly Inspection Version 27.2

FNP-2-STP-23.1 2A COMPONENT COOLING WATER PUMP 05/26/2021

QUARTERLY INSERVICE TEST

FNP-2-STP-23.2 2B COMPONENT COOLING WATER PUMP 03/15/2021

QUARTERLY INSERVICE TEST

FNP-2-STP-23.3 2C COMPONENT COOLING WATER PUMP 04/17/2021

NMP-ES-035-001 Fire Protection Program Implementation VERSION

14.0

NMP-ES-035-003 Fleet Hot Work Instruction VERSION

10.0

NMP-ES-035-003-F01 Hot Work Permit VERSION

4.0

NMP-ES-035-006 Fire Protection Program Impact Screen and Version 13.0

Detailed Reviews

NMP-ES-035-007 Fleet Fire Watch Instruction Version 10.0

NMP-ES-035-014 Fleet Transient Combustible Controls VERSION

5.0

NMP-ES-035-018 NFPA 805 Monitoring Program VERSION

1.1

NMP-ES-035-018 NFPA 805 Monitoring Program 05/03/2021

NMP-ES-036-001 Underground Pipe & Tank Monitoring Program Version 11.1

Implementation

NMP-HP-501-005 Inspection, Repair and Storage of the MSA G1 VERSION

SCBA 2.1

Inspection Type Designation Description or Title Revision or

Procedure Date

NMP-MA-054 General Plant Housekeeping Version 1.2

Work Orders SNC 1122664 Diesel Driven Fire Pump #1 Functional Test 4/25/2021

SNC 1140263 Diesel Driven Fire Pump Inspection 2/11/2021

SNC 553311 Fire Distribution System Flow Test 8/2/2018

SNC 719295 Sprinkler System Piping NDE for Wall Thinning and 9/15/2016

Flow Blockage

SNC 731321 Sprinkler System Piping NDE for Wall Thinning and 4/4/2020

Flow Blockage

11