IR 05000348/2024002

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– Integrated Inspection Report 05000348-2024002 and 05000364-2024002 and Exercise of Enforcement Discretion
ML24212A115
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 08/12/2024
From: Mark Franke
Division Reactor Projects II
To: Coleman J
Southern Nuclear Operating Co
References
EA-24-072 IR 2024002
Download: ML24212A115 (22)
v • d • e


Text

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000348/2024002 AND 05000364/2024002 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Jamie Coleman:

On June 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Joseph M. Farley Nuclear Plant. On July 23, 2024, the NRC inspectors discussed the results of this inspection with John Andrews, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

No NRC-identified or self-revealing findings were identified during this inspection.

One Severity Level (SL) IV violation associated with exercise of enforcement discretion in accordance with Section 3.10, Reactor Violations with No Performance Deficiencies, of the Enforcement Policy is documented in this inspection report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

The violation involved the failure of the C main steam safety valve on the unit 2 B main steam line to lift within the pressure band allowed by the unit 2 technical specifications (TS). The inspectors concluded there was no performance deficiency associated with the violation. The violation was considered for escalated enforcement action because its circumstances aligned with an SL III violation example in Section 6.1.c.2 of the Enforcement Policy. The NRC Enforcement Policy can be found at the NRCs website at https://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.

Based on the facts detailed in the enclosed report, and consultation with the Office of Enforcement and the Regional Administrator, I have been authorized to exercise enforcement discretion in accordance with Section 3.10 of the Enforcement Policy to categorize this violation as an SL IV violation. The NRC concluded that the violation resulted in no, or relatively minimal potential safety impact because (1) other pressure reducing components were available and (2)

an informational risk analysis performed by NRC staff indicated the violation was of very low risk significance.August 12, 2024 If you contest the violation or the 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, Mark E. Franke, Director 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: 05000348/2024002 and 05000364/2024002

Enterprise Identifier: I-2024-002-0018

Licensee: Southern Nuclear Operating Company. Inc.

Facility: Joseph M. Farley Nuclear Plant

Location: Columbia, AL

Inspection Dates: April 1, 2024 to June 30, 2024

Inspectors: A. Alen Arias, Senior Project Engineer J. Bell, Senior Health Physicist B. Bowker, Reactor Inspector J. Diaz-Velez, Senior Health Physicist B. Kellner, Senior Health Physicist P. Meier, Senior Resident Inspector C. Scott, Senior Project Engineer S. Temple, Senior Resident Inspector

Approved By: Mark E. Franke, Director Division of Reactor Projects

Enclosure

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

Main steam safety valve lift pressure outside of TS limits due to setpoint drift Cornerstone Severity Cross-Cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71153 NCV 05000364/2024002-01 Open/Closed EA-24-072 A self-revealed Severity Level (SL) IV non-cited violation (NCV) of Technical Specifications (TS) Limiting Condition of Operation 3.7.1, Main Steam Safety Valves, was identified when a routine lift pressure test revealed that the lift setpoint for the C main steam safety valve, associated with the B main steam line, was higher than allowed by TS. Based on the Licensee Event Report 2023-002-00 submitted by the licensee regarding the issue and inspector evaluation, it was determined that MSSV Q2N11V0011C was inoperable for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> between April 30, 2019, to October 3, 2023, while the unit was in modes 1, 2, and 3.

Additional Tracking Items

Type Issue Title Report Status Number Section LER 05000364/ LER 2024-002-00 for Joseph M. Farley Nuclear 71153 Closed 2024-002-00 Plant, Unit 2 for Manual Reactor Trip due to Loss of Power to the 2A 125 Volt DC Distribution Panel LER 05000364/ LER 2024-002-01 for Joseph M. Farley Nuclear 71153 Closed 2024-002-01 Plant, Unit 2, Manual Reactor Trip due to Loss of Power to the 2A 125 Volt DC Distribution Panel LER 05000364/ LER 2023-002-00 for Joseph M. Farley Nuclear 71153 Closed 2023-002-00 Plant, Unit 2, Main Steam Safety Valve Lift Pressure Outside of Technical Specifications Limits due to Setpoint Drift

PLANT STATUS

Unit 1 began the inspection period at rated thermal power. On April 7, 2024, the unit was shut down for scheduled refueling outage 1R32. On May 9, 2024, the unit was restarted and reached 100 percent rated thermal power on May 18, 2024. The unit remained at or near rated thermal power for the remainder of the inspection period.

Unit 2 operated at or near 100 percent rated thermal power for the entire inspection 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 seasonal hot temperatures for the following systems during the month of May 2024:
  • component cooling water system
  • containment coolers
  • onsite AC power sources

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather due to forecasted severe thunderstorms and potential tornados on April 10, 2024, with potential to impact unit 1 refueling operations during the 2024 spring outage, 1R32 (procedure NMP-OS-017)

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) Emergency diesel generator 1-2A alignment to unit 2 during the unit 2 'B' emergency diesel generator planned maintenance outage on April 1, 2024 (procedures FNP-0-SOP-38.0A and FNP-0-SOP-38.0C)
(2) Unit 1 'B' train low head safety injection system following 1R32 on May 22, 2024 (FNP-1-SOP-7.0)
(3) Unit 2 'A' train component cooling water system during maintenance and testing of the 'C' component cooling water pump on June 10, 2024 (FNP-2-SOP-23.0, and drawing D205002)
(4) Unit 2 'B' train component cooling water system during maintenance and testing of the 'B' component cooling water pump on June 17, 2024 (FNP-2-SOP-23.0; D205002)

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 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 (FAs):

(1) Unit 1 containment on April 26, 2024 (procedure FNP-1-FPP-3.0)
(2) Unit 2 'A' train vital DC (direct-current) room (FA 2-018) on May 23, 2024 (FNP-2-FPP-1.0)
(3) Unit 2 'B' train switchgear room (FA 2-021) on May 23, 2024 (FNP-2-FPP-1.0)
(4) Unit 2 'A' train switchgear room (FA 2-041) on June 11, 2024 (FNP-2-FPP-1.0)
(5) Unit 2 cable spreading room (FA 2-040) on June 11, 2024 (FNP-2-FPP-1.0)
(6) Service water intake structure 'A' train switchgear room (FA-076) on June 11, 2024 (FNP-0-FPP-3.0)

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill (F-2024-007) in the protected area on June 12, 2024.

===71111.08P - Inservice Inspection Activities (PWR)

The inspectors verified that the reactor coolant system boundary, reactor pressure vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities for unit 1 during refueling outage

==1R32 from April 8, 2024, to April 11, 2014.

==

PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01)===

Main article: IP 71111.08

The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:

(1) Ultrasonic Examination

Dye Penetrant Examination

Visual Examination

Welding Activities

The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:

(1)

  • Boric acid evaluations o Condition Report (CR) 11049504, Corrosion Assessment Number:

1E13-2024-001 o CR 10999346, Corrosion Assessment Number: 2E21-2023-001 o CR 11026039, Corrosion Assessment Number: 2E21-2024-001 o CR 10924606, Corrosion Assessment Number: 1E11-2022-003

  • Corrective actions performed for identified evidence of boric acid leaks o CRs 11066253 11066255, 11066256, 11066260, 11066265

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 main control room during the unit 1 shutdown for planned maintenance and refueling outage 1R32 on April 7, 2024.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (3 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 2 risk during a unit 2 'B' emergency diesel generator planned maintenance outage during the week of April 1, 2024
(2) Unit 2 risk while the high voltage switchyard bus 1 was de-energized for an electrical maintenance outage April 17-20, 2024 (procedure NMP-GM-021)
(3) Risk to units 1 and 2 with post-outage work ongoing in the low voltage switchyard while the '1-2A' emergency diesel generator was tagged out for planned maintenance on May 20, 2024 (NMP-GM-021)

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Unit 1 'B' steam generator 'B' main steam isolation valve HV3370B exceeding acceptable stroke time identified on April 7, 2024 (CR 11065585)
(2) Unit 1 'A' steam generator main steam line spring can support cracks identified on April 19, 2024 (CR 11069413)
(3) Unit 1 main steam safety valves following the '1E' steam dump valve failure on May 9, 2024 (CR 11075471)
(4) Unit 2 'B' emergency diesel generator with a jacket water leak discovered during surveillance testing on May 20, 2024 (CR 11080434)

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Permanent removal of the unit 1 pressurizer cubicle grating implemented during the unit 1 refueling outage 1R32 (design change package [DCP] SNC1356127)
(2) Unit 1 nuclear steam service system control and steam generator level control system digital upgrade performed during the unit 1 refueling outage 1R32 in April 2024 (DCP SNC1083454)

71111.20 - Refueling and Other Outage Activities

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

(1) The inspectors evaluated refueling outage 1R32 activities from April 7, 2024, to May 9, 2024.

71111.24 - Testing and Maintenance of Equipment Important to Risk

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

Post-Maintenance Testing (PMT) (IP Section 03.01) (6 Samples)

(1) Unit 2 'B' emergency diesel generator jacket water flex hose replacement and jacket water pump seal replacement during the week of April 1, 2024 (WOs SNC965355 and SNC1129967)
(2) Unit 1 source range detector (NI-32) repair during refueling outage 1R32 (CR 11070860)
(3) Unit 1 power range nuclear instrument (NI-42) testing following replacement on May 1, 2024 (WO SNC1367753)
(4) Unit 1 steam generator level control system digital upgrade power ascension testing performed during the week of May 6, 2024 (procedure FNP-1-SPETP-005)
(5) Unit 2 'B' component cooling water pump testing following planned maintenance on June 17, 2024 (FNP-2-STP-23.2)
(6) Emergency diesel generator '1C' jacket water coupling replacement on June 20, 2024 (FNP-0-SOP-38.0-1C)

Surveillance Testing (IP Section 03.01) (3 Samples)

(1) Unit 1 'A' train loss of offsite power surveillance (FNP-1-STP-80.14; WO 480835) on April 8, 2024, and safety injection with loss of offsite power surveillance performed on April 12, 2024 (FNP-1-STP40.0A, WO SNC480835)
(2) Unit 1 auxiliary building 'A' train battery modified performance testing on April 29, 2024 (FNP-1-STP-905.5; WO SNC715324)
(3) Unit 1 'A' charging pump quarterly surveillance on June 17, 2024 (FNP-1-STP-4.1)

Inservice Testing (IST) (IP Section 03.01) (1 Sample)

(1) Unit 2 'B' charging pump quarterly IST on April 15, 2024 (FNP-2-STP-4.2)

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

(1) Containment purge exhaust isolation valve (penetration 13) on April 27, 2024 (FNP-1-STP-627.0)

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)

The inspectors observed and evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) Licensee surveys of potentially contaminated material leaving the radiologically controlled area.
(2) Workers exiting the radiological controlled area during unit 1 refueling outage 1R32.
(3) Licensee survey and labeling of bagged radioactive materials during unit 1 refueling outage 1R32.

Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)

The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:

(1) Reactor head disassembly/reassembly during 1R32. Radiation work permit (RWP)24-1461 (including As-Low-As-Reasonably-Achievable [ALARA] Plan, RWP, and radiation protection hold points)
(2) Reactor coolant pump maintenance during 1R32. RWP 24-1428 (including ALARA Plan, RWP, respirator use evaluation (Total Effective Dose Equivalent [TEDE]/ALARA evaluation), temporary shielding, and radiation protection hold points)
(3) Unit 1 reactor water storage tank cleanout and inspection. RWP 24-1752 (including ALARA Plan, RWP, respirator use evaluation (TEDE/ALARA evaluation), temporary shielding, and radiation protection hold points)
(4) Unit 1 seal table and in-core work. RWPs 24-1435 (Non-High Rad) and 24-1438 (High Rad)

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)

The inspectors evaluated licensee controls of the following high radiation areas (HRAs) and very high radiation areas (VHRAs):

(1) Unit 1 reactor sump access door on 105-foot elevation in containment (VHRA/Grave Danger)
(2) Unit 1 regenerative heat exchanger on 105-foot elevation in containment (locked high radiation area [LHRA])
(3) Unit 2 volume control tank room 121-foot (LHRA)
(4) HRA controls on the 121, 100, and 83-foot elevations for unit 1 crud burst
(5) HRA controls for reactor cavity work on 155-foot elevation in containment

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (2 Samples)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) Units 1 and 2 spent fuel pool ventilation system filtration units
(2) Units 1 and 2 radiological waste area ventilation system filtration units

Temporary Ventilation Systems (IP Section 03.02) (2 Samples)

The inspectors evaluated the configuration of the following temporary ventilation systems:

(1) High efficiency particulate air filter units HP-NPU-053 and HP-NPU-054, tested October 3, 2023
(2) Vacuum units VAC-048 and VAC-049, tested October 3, 2023

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.

Internal Dosimetry (IP Section 03.03) (3 Samples)

The inspectors evaluated the following internal dose assessments:

(1) Whole body count of carpentry supervisor on June 15, 2023
(2) Whole body count of radiation protection technician on June 15, 2023
(3) Whole body count of worker unable to pass exit monitors on April 9, 2024

Special Dosimetric Situations (IP Section 03.04) (3 Samples)

The inspectors evaluated the following special dosimetric situations:

(1) Declared pregnant worker on January 30, 2023
(2) Declared pregnant worker on March 20, 2024
(3) Extremity monitoring and shallow dose equivalent assigned on September 18, 2022

71124.05 - Radiation Monitoring Instrumentation

Walkdowns and Observations (IP Section 03.01) (10 Samples)

The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:

(1) Personnel contamination monitors, portal monitors, and small article monitors located at the radiologically controlled area exit.
(2) Unit 2, 155-foot elevation, plant vent stack (low/mid/high range gas effluent monitor)

(R-29B)

(3) Unit 2, 120-foot elevation, liquid radwaste processing radiation monitor (R-18)
(4) Unit 2, 120-foot elevation, steam generator blowdown liquid radwaste monitor (R-23B)
(5) Portable friskers located in various locations in the auxiliary building
(6) Portable survey instruments at the radiation protection instruments calibration laboratory
(7) High Purity Germanium (HPGe) and liquid scintillation detectors at the chemistry laboratory
(8) Whole body counter at the dosimetry office in the support building.
(9) Unit 1 main control room radiation monitoring system
(10) Unit 2 main control room radiation monitoring system

Calibration and Testing Program (IP Section 03.02) (15 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1) Mirion People Mover Whole Body Counter - Auxiliary Building, calibrated June 21, 2023
(2) Canberra Argos 5AB, HP-IPC-036A, calibrated March 24, 2024
(3) Canberra Argos 5AB, HP-IPC-037A, calibrated March 23, 2024
(4) Canberra Argos 5AB, HP-IPC-040, calibrated July 24, 2023
(5) Thermo Fisher Scientific - Small Article Monitor (SAM-12), HP-GSD-028A, calibrated August 17, 2023
(6) Thermo Fisher Scientific - Small Article Monitor (SAM-12), HP-GSD-029, calibrated August 10, 2023
(7) Canberra Gamma Exit Monitor (GEM-5), HP-GDS-025, calibrated August 2, 2023
(8) Mirion Telepole II Dose Rate Meter, HP-GMT-289, calibrated March 21, 2024
(9) Mirion Telepole II Dose Rate Meter, HP-GMT-299, calibrated March 19, 2024
(10) Mirion Alpha Beta Particulate Monitor (ABPM 203M), HP-LAS-104A, calibrated February 8, 2024
(11) Mirion Alpha Beta Particulate Monitor (ABPM 203M), HP-LAS-107A, calibrated February 13, 2024
(12) Ludlum 9-3 Ion Chamber Survey Meter, HP-IOC-202, calibrated August 7, 2023
(13) Ludlum Model 30 Neutron Meter, HP-NDR-006, serial number 25014116 (detector Ludlum 42-49, serial number 369649), calibrated July 27, 2023
(14) Ludlum 177-61 Benchtop Counter, HP-GMT-18C, calibrated January 24, 2020
(15) Ludlum 177-61 Benchtop Counter, HP-GMT-011C, calibrated December 11, 2023

Effluent Monitoring Calibration and Testing Program Sample (IP Section 03.03) (3 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1) Unit 2, plant vent stack low/mid/high range gas effluent monitor (R-29B), calibrated December 23, 2023, and October 6, 2023
(2) Units 1 and 2, liquid radwaste processing monitors (R-18), calibrated June 6, 2023, and May 13, 2023, respectively
(3) U1, plant vent stack (particulate, iodine, and noble gases) (R-29C), calibrated November 10, 2021 and October 9,

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, 2023 - March 31, 2024)
(2) Unit 2 (April 1, 2023 - March 31, 2024)

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

(1) Unit 1 (April 1, 2023 - March 31, 2024)
(2) Unit 2 (April 1, 2023 - March 31, 2024)

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) October 1, 2023 - March 31, 2024

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) Unit 1 pressurizer relief tank slow pressure rise identified on May 5, 2024 (CR11076949)

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

Main article: IP 71152
(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in motor driven fire pump maintenance that might be indicative of a more significant safety issue.

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

Main article: IP 71153

The inspectors evaluated the following licensees event reporting determinations to ensure it complied with reporting requirements.

(1) Licensee event report (LER) 05000364/2024-002-00, Manual Reactor Trip due to Loss of Power to the 2A 125 Volt DC Distribution Panel, dated April 15, 2024.

Agencywide Documents Access and Management System (ADAMS) Accession No. ML24106A162. The inspectors determined that the cause of the condition described in the LER was not reasonably within the licensee's ability to foresee and correct, and therefore was not reasonably preventable. No performance deficiency nor violation of NRC requirements was identified. This LER is Closed.

(2) LER 05000364/2024-002-01, Manual Reactor Trip due to Loss of Power to the 2A 125 Volt DC Distribution Panel, dated June 19, 2024. ADAMS Accession No. ML24171A018. The inspectors reviewed the updated LER submittal. The inspectors determined that the cause of the condition described in the LER was not reasonably within the licensee's ability to foresee and correct, and therefore was not reasonably preventable. No performance deficiency nor violation of NRC requirements was identified. This LER is Closed.
(3) LER 05000364/2023-002-00, Main Steam Safety Valve Lift Pressure Outside of Technical Specification Limits due to Setpoint Drift, dated November 30, 2023.

ADAMS Accession No. ML23334A228. The inspection conclusions associated with this LER are documented in this report under Inspection Results section (NCV 05000364/2024002-01). This LER is Closed.

INSPECTION RESULTS

Main steam safety valve lift pressure outside of TS limits due to setpoint drift Cornerstone Severity Cross-Cutting Report Aspect Section Not Severity Level IV Not 71153 Applicable NCV 05000364/2024002-01 Applicable Open/Closed EA-24-072 A self-revealed Severity Level (SL) IV non-cited violation (NCV) of Technical Specifications (TS) Limiting Condition of Operation 3.7.1, Main Steam Safety Valves, was identified when a routine lift pressure test revealed that the lift setpoint for the C main steam safety valve (MSSV) Q2N11V0011C, associated with the B main steam line, was higher than allowed by Based on the Licensee Event Report 2023-002-00 submitted by the licensee regarding TS.

the issue and inspector evaluation, it was determined that MSSV Q2N11V0011C was inoperable for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> between April 30, 2019, to October 3, 2023, while the unit was in modes 1, 2, and 3.

Description:

The MSSVs provide overpressure protection for the secondary side main steam lines by limiting secondary system pressure to 110% (1195 psig) of the steam generators design pressure. The MSSVs also provide overpressure protection for the reactor coolant system (RCS) boundary by providing a heat sink for the removal of energy from the RCS if the preferred heat sink (i.e., condenser) is not available. The MSSVs are designed to limit RCS to 110% (2735 psig) of its design pressure.

On October 3, 2023, while in mode 1, before the Farley Nuclear Plant Unit 2 October 2023 refueling outage 2R32, the as-found lift pressure for MSSV Q2N11V0011C (i.e., C safety valve on the B main steam line) did not meet the acceptance criteria of +/- 3 percent of the setpoint (1102 psig) required for operability per TS Table 3.7.1-2. The valve lifted high at 1140 psig, which is 5 psig outside of its acceptance range of 1069 to 1135 psig. The valve was installed and placed in service in unit 2 on April 26, 2016 (work order [WO] SNC82187).

Additionally, the valve was found within the +/- 3 percent acceptance criteria during the most recent lift test surveillance on April 2, 2019 (WO SNC786539).

On November 30, 2023, Farley submitted Licensee Event Report (LER) 05000364/2023-002-00, Main Steam Safety Valve Lift Pressure Outside of Technical Specification Limits due to Setpoint Drift, (ADAMS Accession No.ML23334A228) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.73, Licensee event report system.

Corrective Actions: The MSSV setpoint was adjusted to within the TS as-left requirement of

+/-1 percent of the setpoint (1102 psig) on October 3, 2023. The same valve was then replaced with a refurbished and tested valve during the unit 2 refueling outage 2R32 (WO SNC1167341). The licensee conducted a cause evaluation (documented in corrective action report [CAR] 529355) that included evaluation of a failure analysis report (technical evaluation

[TE] 1141155) conducted by an offsite vendor. Other than normal setpoint drift, no extenuating circumstance or conditions were identified as the cause of the drift. The licensee conclusions were consistent with the results of the failure analysis. Per industry operating experience, absent any identifying cause, the small drift above setpoint observed on the valve are not outside the range of historical performance for this type of valve and is attributed to normal setpoint drift.

Corrective Action References: CR11012189 and CAR 529355

Performance Assessment:

The NRC determined this violation was not reasonably foreseeable and preventable by the licensee and therefore is not a performance deficiency.

Enforcement:

The NRC exercised enforcement discretion in Enforcement Action EA-24-072, in accordance with Section 3.10 of the Enforcement Policy, because the violation was not associated with a licensee performance deficiency. Specifically, the violation was not attributable to equipment failures that were avoidable by reasonable licensee quality assurance measures or management controls. Therefore, inspectors concluded that there was no performance deficiency associated with MSSV Q2N11V0011C failure to lift within the TS acceptance criteria. The licensee adjusted the valve to within TS limits and completion times, subsequently replaced the valve during the upcoming unit 2 refueling outage (2R32)and conducted a cause evaluation that determined that the observed drift was within the range of historical performance for this type of valve. This enforcement discretion will not be considered in the assessment process of the NRCs Action Matrix.

Severity: The inspectors assessed the severity of the violation using Section 6.1 of the Enforcement Policy. The circumstances of the violation aligned with an SL III violation example in Section 6.1.c.2 of the Enforcement Policy and was considered for escalated enforcement action. However, the NRC concluded that the violation resulted in no, or relatively minimal potential safety impact because

(1) other main steam and RCS pressure reducing components were available to support the systems function, and
(2) an informational risk analysis performed by NRC staff indicated the violation was of very low risk significance. Therefore, the NRC staff and determined the significance is appropriately characterized at SL IV.

Violation: Farley Nuclear Plant Unit 2 TS LCO 3.7.1, Main Steam Safety Valves, requires five operable MSSVs per steam generator with a lift setting of +/- 3 percent of the value corresponding to each valve in accordance with TS Table 3.7.1-2, while the unit is in modes 1, 2, and 3. Table 3.7.1-2 specifies that the corresponding lift setpoint of MSSV Q2N11V0011C is +/- 3 percent of 1102 psig. With one MSSV inoperable, Required Action A.1, requires reactor power to be reduced to less than or equal to 87 percent rated thermal power within four hours. If the required action and associated completion time is not met, Required Action C.1, requires that the unit to be in mode 3 within six hours.

Contrary to the above, for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> within the period from April 30, 2019, to October 3, 2023, MSSV Q2N11V0011C was inoperable because it failed to meet the lift setpoint established in TS Table 3.7.1-2 while the unit was in modes 1, 2, and 3. With MSSV Q2N11V0011C inoperable, the licensee failed to take Required Action A.1 to reduce power within four hours and Required Action C.1 to place the unit in mode 3 within six hours.

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 July 23, 2024, the inspectors presented the integrated inspection results to John Andrews, Plant Manager, and other members of the licensee staff.
  • On April 11, 2024, the inspectors presented the radiation safety inspection results to Edwin Dean, Site Vice President, and other members of the licensee staff.
  • On April 11, 2024, the inspectors presented the inservice inspection results to Edwin Dean, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Action Condition Report CR 11079418

Documents (CR)

71111.01 Procedures NMP-GM-025 Seasonal Readiness Process 05/13/2024

71111.15 Corrective Action CR 11080434

Documents

71111.24 Corrective Action CR 11071519

Documents

71111.24 Procedures FNP-1-STP-228.6 NIS Power Range Channel N42 Calibration N1C55NE0042 Ver. 81.0

71111.24 Procedures FNP-1-STP-4.1 1A Charging Pump Quarterly Inservice Test Ver. 81.0

71111.24 Procedures FNP-1-STP-627.0 Local Leak Rate Testing of Containment Penetrations Ver. 63.0

71111.24 Procedures FNP-2-STP-23.2 2B Component Cooling Water Pump Quarterly Inservice Test Ver. 39.0

71111.24 Work Orders SNC1048142 OHI -N1C55NI0042-Replace TRIAX connectors for U1 NI42 05/01/2024

NIS/Excore Detectors

71111.24 Work Orders SNC1237420 U1 7300-Q1H11NGPIC2505-Power Ascension Test-Process 06/10/2024

I&C System 7300

71111.24 Work Orders SNC1367753 OHI - N1C55NE0042A and N1C55NE0042B - Replace 05/01/2024

Upper and Lower Detectors IAW FNP-1-IMP-228.5

71111.24 Work Orders SNC1642064 Q2P17P001B - FNP-2-STP-23.2 l 2B CCW PMP Quarterly 06/18/2024

71111.24 Work Orders SNC1772453 AEA - Penetration 13 - CTMT Purge Exhaust excessive

LLRT leakage

71124.01 ALARA Plans Farley Nuclear Plant U2R29 Refueling Outage ALARA 03/12/2024

Report (10/8/23-11/17/23)

71124.01 Calculations Fleet Technical Position Paper for the Conversion of Smear

Beta-Gamma Activity From mRad/h to Disintegrations Per

Minute (dpm)

71124.01 Corrective Action CRs 11018918, 11019626, 11022219, 11030825, and 11032018 Various

Documents

71124.01 Miscellaneous High Radiation/Locked High Radiation Area Key Log 04/04/2024

71124.01 Miscellaneous Facility Alpha Characterization Study - Farley 01/25/2024

71124.01 Miscellaneous Unit 1 and 2 Spent Fuel Pool Inventory Log [Non-Fuel/Trash]01/20/2022

71124.01 Procedures FNP-0-RCP-126 Special Radiological Controls for Reactor Coolant System Ver. 1.0

(RCS) Degas and Crud Burst

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.01 Procedures NMP-AD-029 Preparation and Reporting of Regulatory Assessment Ver. 3.2

Performance Indicator Data and the Monthly Operating

Report

71124.01 Procedures NMP-HP-204 ALARA Planning and Job Review Ver. 10.5

71124.01 Procedures NMP-HP-205-001 Farley Site Specific Temporary Shielding Information Ver. 1.0

71124.01 Procedures NMP-HP-302-001 Radiological Key Control Ver. 6.0

71124.01 Radiation Plant Farley Routine Radiological Survey Frequency List 04/06/2024

Surveys

71124.01 Radiation Radiological Spent Fuel Storage lnstallation (ISFSI) 05/25/2023

Surveys Information

Survey (RadIS) #

2964

71124.01 Radiation RadIS # 163822 Spent Fuel Storage lnstallation (ISFSI) 07/14/2023

Surveys

71124.01 Radiation RadIS # 168039 Solidification and Dewatering Facility (SSDF) 03/07/2024

Surveys

71124.01 Radiation RadIS # 168474 Unit 1 155 ft. Containment [Initial Entry after shutdown] 04/07/2024

Surveys

71124.01 Radiation RadIS # 168475 Unit 1 129ft Containment [Initial Entry after shutdown] 04/07/2024

Surveys

71124.01 Radiation RadIS # 168476 Unit 1 105ft Containment O/S Biowall [Initial Entry post 04/07/2024

Surveys shutdown]

71124.01 Radiation RadIS # 168477 Unit 1 105ft Containment Inside Biowall [Initial Entry post 04/07/2024

Surveys shutdown]

71124.01 Radiation RadIS # 168488 Unit 1 A RCP Cubicle [Initial Entry after shutdown] 04/07/2024

Surveys

71124.01 Radiation RadIS # 168520 Unit 1 105ft Containment [Inside bio-wall to downgrade 04/08/2024

Surveys posting after crud burst clean-up]

71124.01 Radiation RadIS # 168538 Unit 1 A/B 121ft piping penetration room [Down grade 04/08/2024

Surveys posting after Crud Burst]

71124.01 Radiation RadIS # 168540 Unit 1 A/B 100ft piping penetration room [Down grade 04/08/2024

Surveys posting after Crud Burst]

71124.01 Radiation RadIS # 168542 Unit 1 A/B Monday 83ft [Down grade posting after Crud 04/08/2024

Surveys Burst]

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.01 Radiation RadIS #168543 Unit 1 RHR Pump Rooms [Down grade posting after Crud 04/08/2024

Surveys Burst]

71124.01 Self-Assessments Pre-Fleet RP NOS audit Check-In Self-Assessment 05/25/2023

71124.01 Self-Assessments Fleet-RP-2023 Audit of Radiation Protection (Farley, Hatch, and Vogtle 1&2)06/06/2023

71124.03 Corrective Action CRs 10926363, 10957472, 11066290, and 11002557 Various

Documents

71124.04 Corrective Action CRs 11043344 and 11022219 Various

Documents

71124.04 Corrective Action CR 11063976 NRC identified a procedure enhancement for a Whole-Body 04/01/2024

Documents Counting

Resulting from

Inspection

71124.05 Corrective Action CRs 10938833, 10957472, 10999269, and 11029306 Various

Documents

71124.05 Corrective Action CRs 11063188, 11063200, 11063976, 1106332, 11064328, and Various

Documents 11063187

Resulting from

Inspection

71151 Miscellaneous Electronic Dosimeter (ED) Dose and Dose Rate Alarm Log Various

(October 1, 2023 through April 10, 2024)

71152S Corrective Action CRs 11085954 and 11090238 Various

Documents

71153 Corrective Action Corrective Action B Loop Main Steam Safety Valve (MSSV) Q2N11V0011C 02/12/2024

Documents Report (CAR) failed high during setpoint verification testing

29355

71153 Drawings D-205033 Unit 2 - P&ID - Main Steam and Auxiliary Steam System Ver. 44.0

71153 Engineering APR-TANL-TM-Farley Unit 2 Evaluation of Main Steam Safety Valve 06/25/2024

Evaluations AA-000002 Elevated Pressure for a Justification of Past Operability

(JPO)

71153 Miscellaneous NMS Traveler 23-NWS Technologies Failure Analysis Report: Farley Dresser Rev. 0

380 MSSV, Model 3707RA-RT22 (SN: BP09820)

71153 Procedures FNP-2-STP-608.1 Main Steam Safety Valve Operational Test by Vendor Ver. 19.0

71153 Work Orders SNC1074173 IST - Q2N11V0011C. B Loop MS Safety - FNP-2-STP-608.1 10/16/2023

71153 Work Orders SNC1081243 IST - Q2N11V0011D. B Loop MS Safety - FNP-2-STP-608.1 10/15/2023

Inspection Type Designation Description or Title Revision or

Procedure Date

71153 Work Orders SNC1120197 IST - Q2N11V0011E. B Loop MS Safety - FNP-2-STP-608.1 10/05/2023

71153 Work Orders SNC1167341 IST - Q2N11V0011C. B Loop MS Safety - Remove for 10/20/2023

Inspection/Repair

71153 Work Orders SNC786539 IST - Q2N11V0011C. B Loop MS Safety - FNP-2STP-608.0 04/02/2019

20

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