NL-18-0859, Unit 2 - Reply to a Notice of Violation: EA-17-204

Unit 2 - Reply to a Notice of Violation: EA-17-204

ML18171A385
Person / Time
Site:	Farley
Issue date:	06/20/2018
From:	Madison D Southern Nuclear Operating Co
To:	Document Control Desk, NRC/RGN-II
References
EA-17-204, NL-18-0859 IR 2018014
Download: ML18171A385 (5)

Text

~ Southern Nuclear Dennis R. MadiiOfl VIce Pnlsldent *Farley Joseph M. Farley Nuclear Plant 7388 North State Hwy 95 Columbia. Alabama 36319 334 814.4511 let 334 81 44575 lax June 20, 2018 dnnsd1so0 southemco.com Docket Nos.: 50.348 NL-18-0859 5().364 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Farley Nuclear Plant - Unit 1 and Unit 2 Replv to a Notice of Violation: EA-17-204

Reference:

NRC letter to Southern Nuclear Operation Company, Joseph M. Farley Nuclear Plant -Inspection Report 0500034812018014 and 0500036412018014; Investigation Report No. 2*2017-014; and Notice of Violations (EA-17-204}

Ladies and Gentlemen:

In accordance with the provisions of 10 CFR 2.201, the Nuclear Regulatory Commission (NRC) has issued to Southern Nuclear Operating Company (SNC) a violation, as restated in the enclosure. SNC acknowledges and conaus with the violation. This letter constitutes the required response submittal.

This letter contains no new NRC commitments. If you have any questions, please contact Gene Surber, Ucenslng Manager, at 334.814.5448.

RespectfuUy submitted,

\

~.C'7/~.._

D. R. Madison DRMIRGS

Enclosure:

Reply to Violation EA-17-204 cc: Regional Administrator, Region II NRR Project Manager- Farley Nuclear Plant Senior Resident Inspector- Farley Nuclear Plant RType: CFA04.054

Joseph M. Farley Nuclear Plant- Unit 1 and Unit 2 Reply to a Notice of Violation; EA-17-204 Enclosure Reply to Violation EA-17-204

U. S. Nuclear Regulatory Commission Enclosure to NL-18-0859 Reply to Violation EA-17-204- Page 1 RESTATEMENT OF VIOLATION During an NRC investigation completed on November 16,2017, the following violations of NRC requirements were identified:

• !* SL IV NOV 05000348,05000364/2018014-01; Failure to Complete System Operator (SO) Rounds as Required per Procedures.

• !* SL IV NOV 05000348,05000364/2018014-02; Failure to Provide Complete and Accurate Information Related to System Operator Rounds A. Technical Specification 5.4.1.a, states that 'Written procedures shall be established, implemented, and maintained covering the following activities: The applicable procedures recommended in RG 1.33, Rev. 2, Appendix (App.). A, Feb. 1978."

Regulatory Guide (RG) 1.33, Revision (Rev.) 2, App. A, lists typical safety-related activities that should be covered by written licensee procedures. Item 1.h names administrative procedures for log entries and record retention as one of the written procedures licensees should cover.

Farley Procedure, NMP-OS-007-001, "Conduct of Operations Standards and Expectations,"

Version 14.4, sets forth standards and expectations on various Plant Operations topics, and Section 4.13 sets forth standards and expectations on log keeping and watch station rounds.

• Section 4.13.2(2), Narrative Logs, states, "Log entries are made in a timely manner. Entries provide enough detail for events to be reconstructed at a later date. A log is a legal document and is therefore accurate, factual, complete and clear."

• Section 4.13.2(3), Watch Station Rounds, states, The recording of operating logs is performed during Watch Station Rounds in accordance with an approved schedule. Required readings are taken unless the associated equipment or system is out of service. Readings not taken are noted with a documented reason."

Farley Procedure, FNP-0-SOP-0.11, 'Watch Station Tours and Operator Logs," Version 27.0, provides guidance for conducting watch station tours and use of Operator logs.

Section 6.0, Records, states, "Documents created using this procedure will become QA Records when completed unless otherwise stated."

REASON FOR THE VIOLATION The station conducted a Root Cause of the event. At SNC, personal accountability is a trait of a positive nuclear safety culture. All individuals are expected to take personal responsibility for nuclear safety and uphold the highest levels of integrity. The Root Cause Team determined that the SO's actions of willful falsification of logs during operator rounds was the root cause.

U. S. Nuclear Regulatory Commission Enclosure to NL-18-0859 Reply to Violation EA-17 -204 - Page 2 CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED A Root Cause was conducted and the team (ACT} reviewed the SO information along with an extent of condition review in the areas of fire watches, security, and chemistry. No falsification or integrity issues were identified during the extent of condition review.

The ACT concluded that the falsification of plant records would have been less likely to occur and may have been detected earlier if OE had been effectively implemented and corrective actions for previous integrity issues at FNP had been more broadly applied to other areas.

The SO's involved in the falsification were performance managed. Additionally, the SNC fleet developed and implemented a procedural requirement to perform periodic random verification of records for Operators, Fire watches, and Security Officers rounds to verify that employees are entering the rooms required for their associated logs and the times spent in the rooms is adequate to perform the assigned duties.

Based on the Vogtle event occurring in late 2016, which precipitated the FNP extent of condition investigation, SNC conducted fleetwide training on Upholding our Values (Integrity). This training was based on the research of Professor Dan Ariely, a behavioral economist from Duke University.

The Training included the four Integrity significance factors described in Dr. Ariely's research:

Rationalization, Timely Consequences, Opportunities, and Ethical Reminders.

SNC revised NMP-OS-007-007, Rounds and Log Keeping:

a. Revise step 3.7.3 to specifically state the operator must review the rounds face to face with the supervisor at the completion of the rounds to discuss any issues.

b. Revise step 4.2.1.8 to require face to face debriefings.

c. Added a statement requiring the operator taking logs with the handheld device to use their personal login only (not another person's login).

To better ensure management oversight of SO activities, SNC has revised NMP-OS-007, Conduct of Operations, to clarify that the chain of command for SO's is a single supervisor authority.

SNC enhanced the Operating Experience Program (NMP-GM-008) to better facilitate thorough Extent of Condition reviews. The changes to the procedure provided guidance for an extent of condition review for NRC items like Generic Letters, Information Notices, Bulletins, Regulatory Issue Summaries and other sources of operating experience. The purpose of this action was to ensure that work organizations/disciplines beyond those specifically described in these types of operating experience documents are appropriately considered for actions.

SNC also enhanced the Corrective Action Program through the revision of NMP-GM-002-GL03 (Cause Analysis Guideline) to require that an extent of condition be performed on integrity analysis.

In addition, SNC revised the Corrective Action Program Instruction procedure (NMP-GM-002-001) to have CAs evaluated for potential integrity issues. If a potential integrity issue were to be identified, the procedure directs the performer to notify the appropriate Department Manager.

U.S. Nuclear Regulatory Commission Enclosure to NL-18-0859 Reply to Violation EA-17 -204 - Page 3 Following completion of the corrective actions, Farley documented two events in which an employee recognized and reported a potential integrity issue. In both instances, a non-supervisor employee identified the issue and took the appropriate actions to report the issue to management.

This demonstrates that station employees have internalized the referenced training and expectations regarding integrity at FNP.

CORRECTIVE STEPS THAT WILL BE TAKEN Farley will continue to perform audits of rounds as a long-term corrective action in accordance with the newly developed procedure for rounds verification (NMP-AD-051) and perform the previously discussed log-keeping and oversight activities.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Corrective Actions to address the identified violation are complete. Farley is in full compliance with applicable regulatory requirements.