Text

Integrated Inspection Report 05000348/2022002 and 05000364/2022002
	ML22213A070
Person / Time
Site:	Farley
Issue date:	08/12/2022
From:	Alan Blamey; NRC/RGN-II/DRP/RPB2
To:	Gayheart C; Southern Nuclear Company
References
	IR 2022002
	Download: ML22213A070 (14)
	v • d • e

August 10, 2022

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000348/2022002 AND 05000364/2022002

Dear Ms. Gayheart:

On June 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Joseph M. Farley Nuclear Plant. On July 26, 2022, 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.

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, 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:

As stated

Inspection Report

Docket Numbers:

05000348 and 05000364

License Numbers:

NPF-2 and NPF-8

Report Numbers:

05000348/2022002 and 05000364/2022002

Enterprise Identifier:

I-2022-002-0014

Licensee:

Southern Nuclear Operating Company, Inc.

Facility:

Joseph M. Farley Nuclear Plant

Location:

Columbia, AL

Inspection Dates:

April 01, 2022 to June 30, 2022

Inspectors:

J. Bell, Resident Inspector

P. Cooper, Senior Reactor Inspector

S. Downey, Senior Reactor Inspector

P. Meier, Senior Resident Inspector

S. Temple, 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

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

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000348,05000364/20 21003-02 Cask Transfer Operations Outside of the Fuel Handling Building 60855 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 95 percent RTP, coasting down to approximately 75 percent RTP over ten days in preparation for a planned refueling outage on April 10, 2022. On April 10, 2022, unit 2 entered mode 3 and began the outage (2R28). Following the refueling outage, on May 2, 2022, unit 2 reactor was taken critical and entered mode 1 on May 3, 2022. Over a period of approximately seven days, RTP was increased with various hold points for testing until May 9, 2022, when unit 2 achieved approximately 100 percent RTP. Unit 2 remained at approximately 100 percent RTP until June 11, 2022, when RTP was lowered to approximately 90 percent due to condenser cooling tower issues. On June 13, 2022, unit 2 returned to approximately 100 percent RTP and held there 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 activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of summer and high temperatures for the following systems (NMP-GM-025):

emergency diesel generators on May 17, 2022

river water intake on May 18, 2022

low voltage switchyard and transformers on May 19, 2022

service water pond (ultimate heat sink) on May 19, 2022

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 2 'B' residual heat removal system while in-service with unit 2 in mode 5 prior to the 'A' train emergency diesel generator loss of offsite power and sequencer load shedding circuit testing on April 11, 2022 (FNP-2-STP-7.0, D205041, D205038)

(2) Unit 2 turbine driven auxiliary feedwater system while both trains of the motor driven auxiliary feedwater system were in-service following a refueling outage on May 2, 2022 (D205007, D205033)

(3) Unit 2 'A' train emergency diesel generator alignment during maintenance of the unit 2 'T' motor control center impacting the operability of the unit 2 'B' train emergency diesel generator on May 23 and 24, 2022 (FNP-0-SOP-38.0-1-2A; FNP-0-SOP-38.0-2C)

(4) Fire protection pump house and alternate service water supply to the fire protection storage tanks due to normal supply water issues on June 15, 2022 (CR10887777; D200013; D170366)

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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 (FA):

(1) Unit 2 containment on April 29, 2022 (FNP-2-FPP-3.0)

(2) Unit 2 cable spreading room (FA 2-040) on May 12 and 13, 2022 (FNP-2-FPP-1.0)

(3) Unit 2 'A' train 4kv switchgear room (FA 61) on May 12 and 13, 2022 (FNP-2-FPP-1.0)

(4) Unit 2 component cooling water heat exchanger room (FA 2-009) on May 12, 2022 (FNP-2-FPP-1.0)

(5) Unit 2 'B' emergency diesel generator room (FA 59) on May 12, 2022 (FNP-0-FPP-2.0)

71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)

Main article: IP 71111.08

(1) The inspectors evaluated pressurized water reactor non-destructive testing by reviewing the following examinations from April 18 to April 22, 2022:

1. Magnetic particle examination:

a.

Weld 2F, flange to pipe weld, ASME Class 3; this included a review of the associated welding activities b.

Weld 4F, pipe to valve weld, ASME Class 3; this included a review of the associated welding activities

2. Ultrasonic examination

a.

Weld APR1-4103-6-RB, pipe to pipe weld, ASME Class 1 b.

Weld APR1-4204-3-RB, pipe to elbow weld, ASME Class 1 c.

Weld APR1-4204-4-RB, pipe to elbow weld, ASME Class 1 d.

Weld APR1-4304-19-RB, pipe to valve weld, ASME Class 1

3. Visual examination

a.

Bare metal visual of the reactor pressure vessel bottom head, ASME Class 1 The inspectors also evaluated the licensees boric acid control program performance.

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 the unit 2 down power in preparation for the unit 2 refueling outage on April 10, 2022.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator continuing training during a simulator exam scenario involving various plant malfunctions and a steam generator tube rupture on June 21, 2022 (Operations Training Simulator Exam Scenario #42).

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 and unit 2 instrument air system due to an increase of unreliability issues (CR10873325)

(2) Emergency diesel generator replacement of obsolete and unreliable relays (J-relays)for the 1-2A emergency diesel generator and unit 1 and unit 2 'B' train emergency diesel generators (WO SNC1107843; TE 1088756)

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) Unit 2 turbine driven auxiliary feedwater pump signal isolator, including vendor oversight of commercial grade dedication services (purchase order SNA10244408)

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (6 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 risk during 'A' train emergency diesel generator loss of offsite power and sequencer load shedding circuit testing on April 12, 2022 (FNP-2-STP-80.14; NMP-DP-001)

(2) Unit 2 'A' steam generator feed pump auto stop oil leak following the spring 2022 refueling outage (2R28) in May 2022 (CR 10878386)

(3) Realigning the unit 1 main generator output leads isophase bus duct cooling system to the redundant train on May 16, 2022 (FNP-1-SOP-28.1)

(4) Unit 2 'T' motor control center planned maintenance outage impacting the operability of the unit 2 'B' emergency diesel generator on May 23 and 24, 2022 (WO SNC551526)

(5)

'1-2A' emergency diesel generator planned maintenance outage on June 6, 2022 (WO SNC1328851)

(6) Unit 1 'A' spent fuel cooling system planned maintenance impacting component cooling water and operability of the 'B' train high head safety injection system on June 28, 2022 (WO SNC1001786)

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 2 'C' emergency diesel generator service water supply leak identified on April 11, 2022 (CR 10872904)

(2) Unit 2 containment atmosphere sample system high leakage identified on April 4, 2022 (CR 10871345)

(3) Unit 2 containment personnel inner door failed as-found local leak rate testing on April 10, 2022 (CR 10872672)

(4) Movable incore detection system issue and ability to meet surveillance requirements before increasing unit 2 reactor power following the spring 2022 refueling outage (2R28) on May 3, 2022 (CR 10878644)

(5) Unit 2 'A' main steam isolation valve (3370A) strike plate out of alignment identified on May 23, 2022 (CR10882966)

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (3 Samples)

The inspectors evaluated the following permanent modifications:

(1) Unit 2 encapsulation vessel removal from residual heat removal and containment sump motor operated valves (Q2E11MOV8811B and Q2E13MOV8826B respectively)during the spring 2022 outage in April 2022 (SNC1153267)

(2) Unit 2 'B' emergency diesel generator synchronizing switch replacement on the emergency power board during the spring 2022 outage in April 2022 (DCP SNC351984; WO SNC1136433)

(3) Unit 2 component cooling water motor operated valve (Q2P17MOV3046) actuator modification during the spring 2022 outage in April 2022 (SNC1061951)

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)

The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:

(1) Unit 2 'B' start-up transformer pothead replacements performed during the spring 2022 refueling outage (2R28) in April 2022 (WO SNC1139252; DECP SNC1079284)

(2) Replacement of the low head safety injection to reactor coolant system hot leg valve control room hand switch during the spring 2022 refueling outage (2R28) in April 2022 (WO SNC1136429)

(3) Main steam isolation valve actuator replacements performed during the spring 2022 refueling outage (2R28) in April 2022 (WOs SNC958566, SNC968014, SNC968013)

(4) Replacement of the pressurizer pressure transmitter (PT-456) during the spring 2022 refueling outage (2R28) in April 2022 (WO SNC584320)

(5) Unit 2 auxiliary building 'B' 125 volt battery bank testing following battery bank replacement completed on April 22, 2022 (SNC10572072, FNP-2-STP-905.1, FNP-2-STP-905.4, FNP-2-STP-905.6)

(6) Pressurizer safety valve, Q2B13V0031B, following replacement during the Spring 2022 outage in April 2022 (WO SNC963853)

(7) Unit 2 'B' emergency diesel generator testing following the air start solenoid valve rebuild on May 23, 2022 (WO SNC583613)

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated unit 2 refueling outage (2R28) activities from April 10 to May 3, 2022.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (4 Samples)

(1) Unit 1 and 2 containment tendon and concrete surveillance conducted November 2021 through January 2022 (FNP-2-STP-609.0; REP-1176-510)

(2) Unit 2 'A' train loss of offsite power and safety injection test on April 16, 2022 (FNP-2-STP-40.0.A)

(3) Unit 1 'C' service water pump 'B' train automatic circuitry test on May 26, 2022 (FNP-1-STP-24.10)

(4) Unit 1 'C' charging pump quarterly surveillance test on June 1, 2022 (FNP-1-STP-4.3)

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Unit 2 turbine driven auxiliary feedwater pump comprehensive test on April 4, 2022 (FNP-2-STP-22.32; WO SNC955259)

Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)

(1) Containment purge system local leak rate testing performed toward the end of the unit 2 spring 2022 refueling outage (2R28) in April 2022 (FNP-2-STP-627 & 627.1)

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) Inspectors observed a full participation drill involving a simulated fuel drop in the spent fuel pool room and a mode 1 loss of coolant accident that eventually resulted in a release requiring a general emergency with protective action recommendations on June 14, 2022.

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) A licensed operating crew during a simulator exam (Scenario #42) on June 21, 2022, that involved a drill and exercise performance indicator opportunity.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS09: Residual Heat Removal Systems (IP Section 02.08)===

Main article: IP 71151

(1) Unit 1 (April 1, 2021 - March 31, 2022)

(2) Unit 2 (April 1, 2021 - March 31, 2022)

MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 1 (April 1, 2021 - March 31, 2022)

(2) Unit 2 (April 1, 2021 - March 31, 2022)

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

Main article: IP 71152

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Individual inadvertently crossed a contaminated area boundary (CR 10879918)

(2) Overflow of the unit 2 refueling cavity during the spring 2022 refueling outage on April 24, 2022 (CR 10875935)

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 60855 - Operation Of An ISFSI The unresolved item (URI) regarding "Cask Transfer Operations Outside of the Fuel Handling Building" in Inspection Report 05000348,05000364/2021003-02 has been closed to the Very Low Safety Significance Resolution Process (VLSSIR). Additional information is documented in the results section of this inspection report.

INSPECTION RESULTS

Very Low Safety Significance Issue Resolution Process: Cask Transfer Operations Outside of the Fuel Handling Building 60855 This issue is a current licensing basis question and inspection effort is being discontinued in accordance with the Very Low Safety Significance Issue Resolution (VLSSIR) process. No further evaluation is required.

Description:

The inspectors identified that at the Farley Nuclear Plant, the licensee performs cask transfer operations outside of the fuel handling building. Following this operation, a mating device from the HI-STORM is removed, leaving the MPC within the HI-STORM exposed to natural phenomena and after a short duration the HI-STORM lid is placed onto the HI-STORM.

Licensing Basis: 10 CFR 72.122 (b)(2), states, in part, that Structures, systems, and components important to safety must be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, lighting, hurricanes, floods, tsunami, and seiches, without impairing their capability to perform safety functions.

Additionally, 10 CFR 72.212 (b)(6), states that the general licensee must, review the Safety Analysis Report referenced in the CoC or amended CoC and the related NRC Safety Evaluation Report, prior to use of the general license, to determine whether or not the reactor site parameters, including analyses of earthquake intensity and tornado missiles, are enveloped by the cask design bases considered in these reports. The results of this review must be documented in the evaluation made in paragraph (b)(5) of this section.

The HI-STORM 100 FSAR, discusses the specific configurations deterministically analyzed by the CoC holder. Specifically, Section 11.2.6.2, states that the analyses provided in Section 3.4 also shows that the tornado missiles do not penetrate the storage overpack or HI-TRAC transfer cask to impact the MPC. The result of the tornado missile impact on the storage overpack or HI-TRAC transfer cask is limited to damage of the shielding.

The configuration identified at Farley where the lid of the overpack and the HI-TRAC transfer cask is not installed is different than that discussed in the HI-STORM 100 FSAR Section 11.2.6.2 and as analyzed for tornados in FSAR Section 3.4 and is therefore deterministically unanalyzed. However, the FSAR indicates that other configurations than those analyzed may occur as part of routine operations. Specifically, the HI-STORM FSAR, section 11.2.6.1 states the transfer of the MPC from the HI-TRAC transfer cask to the overpack may be performed at the unsheltered ISFSI concrete pad.

In the NRCs Safety Evaluation Report, the NRC states, that F3.4 The applicant has met the requirements of 10 CFR 72.122(b) and

(c) and 10 CFR 72.24(c)(3). The structures, systems, and components important to safety are designed to accommodate the combined loads of normal, off-normal, accident, and natural phenomena events with an adequate margin of safety. Stresses at various locations of the cask for various design load are determined by analysis. Total stresses for the combined loads of normal, off-normal, accident, and natural phenomena events are acceptable and found to be within the limits of applicable codes, standards, and specifications.

The inspection staff believe that, based on information gathered to date, uncertainty exists in the Farley Nuclear Plant licensing basis for the short-term operation where the cask transfer operation occurs outside the fuel handling building. In order to resolve this uncertainty, it would be necessary to conduct further investigation to determine the scope and level of detail of the staffs original licensing review, in addition to other relevant information, to resolve the licensing basis for this short-term evolution.

Significance: A safety significance evaluation was performed utilizing the Safety Significance Determination Template (ADAMS Accession No. ML19302F568) by inspection staff within the Office of Nuclear Material Safety and Safeguards. To assess the safety significance of the issue, the inspection staff evaluated the associated change in risk, impacts to the safety margin, maintenance of defense-in-depth, and the opportunity for monitoring. Although short term evolutions are generally undefined, the inspection staff included the following assumptions in their evaluation.

1. The configuration in question, is the only configuration where uncertainty exists in the

licensing basis for the applicability of 72.122(b)(2) to withstand the effects of tornado missiles

2. An exposure time of approximately 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months per cask, approximately four casks per

year, and a seamless flow of operation with no operating equipment malfunctions (16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months ).

3. Adequate administrative controls are in place to ensure the configuration is not

present during severe weather and those controls describe actions to be taken if severe weather is predicted or issued for the area to place equipment in a safe condition To evaluate the change in risk, the inspector utilized insights from the Bounding Generic Risk Assessment For Selected Plant Systems Portions Of Which Are Not Protected From Tornado-Generated Missiles (Agencywide Documents Access and Management System (ADAMS) at Accession No. ML14114A556). For ISFSI handling operations, generically, the vulnerable configuration would be typically limited to a few weeks of exposure time per year, as detailed above, as opposed to continuous exposure which would result in additional conservatism to the results documented in the NRR generic analysis.

To assess the impacts to safety margin the inspector utilized insights from Regulatory Guide 1.76, Design-Basis Tornado for Nuclear Power Plants which provides guidance for selecting the design-basis tornado and design-basis tornado-generated missiles. The Holtec design basis tornado is assumed to have a 360-mph speed, which is consistent with the initial version of RG 1.76 (issued in 1974). However, Revision 1 to RG 1.76 (issued in 2007)references a maximum rotational wind speed of 230 mph for the central portion of the United States (encompassing the area associated with Farley) which would result in additional margin.

The inspector reviewed the design and construction of the MPC to evaluate the available defense-in-depth. The inspector identified that the tornado missile would have to cause both damage to the confinement boundary, and significantly damage the structure of the MPC to cause fuel damage, loss of cooling, or loss of criticality safety. Additionally, the administrative controls for severe weather provide additional operational defense-in-depth.

The opportunity for monitoring of the issue continues through the NRCs ISFSI oversight program. Inspectors perform inspections onsite in accordance with the frequency specified in IMC 2690, Inspection Program for Storage of Spent Reactor Fuel and Reactor-Related Greater-than-Class-C Waste at Independent Spent Fuel Storage Installations and for 10 CFR Part 71 Transportation Packagings.

The inspection staff concluded that the change in risk was very low, that adequate safety margin is retained, that sufficient defense-in-depth in maintained, that there is adequate opportunity for monitoring, and on the whole the issues safety significance appears to be very low.

Technical Assistance Request: A technical assistance request (TAR) was not initiated.

Unresolved Item Closure: The URI identified as 05000348,05000364/2021003-02 "Cask Transfer Operations Outside of the Fuel Handling Building," is closed

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On July 26, 2022, the inspectors presented the integrated inspection results to Mr.

Delson Erb and other members of the licensee staff.

On April 21, 2022, the inspectors presented the Baseline ISI Exit Meeting inspection results to Delson Erb, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Corrective Action

Documents

CRs (by number)

10791587, 10834639, 10834837, 10844712, 10857401,

10874962

S22FNP2UT005

Ultrasonic Examination of Component APR1-4103-6-RB

04/15/2022

S22FNP2UT010

Ultrasonic Examination of APR1-4304-19-RB

04/18/2022

S22FNP2UT027

Ultrasonic Examination of Weld APR1-4204-3-RB

04/21/2022

S22FNP2UT08

Ultrasonic Examination of Weld APR1-4204-4-RB