NL-23-0825, Reply to Notice of Violation EA-23-080 and Readiness for 95001 Inspection

Reply to Notice of Violation EA-23-080 and Readiness for 95001 Inspection

ML23318A473
Person / Time
Site:	Farley
Issue date:	11/14/2023
From:	Coleman J Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, NRC/RGN-II, Document Control Desk
References
NL-23-0825
Download: ML23318A473 (1)

Text

3535 Colonnade Parkway Birmingham, AL 35243 205 992 5000 Regulatory Affairs November 14, 2023 Docket No.:

50-348 NL-23-0825 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant, Unit 1 Reply to Notice of Violation EA-23-080 and Readiness for 95001 Inspection Ladies and Gentlemen:

By letter dated October 19, 2023, the Nuclear Regulatory Commission (NRC) staff notified Southern Nuclear Operating Company (SNC) of a Notice of Violation (NOV) and associated White Finding in Inspection Report 05000348/2023091. The violation states that SNC failed to identify and correct a condition adverse to quality resulting in the inoperability of the 1B emergency diesel generator (EDG). SNC has implemented corrective steps and completed a root cause evaluation of the issue. Pursuant to the provisions of 10 CFR 2.201, SNC submits the required response to the violation as the Enclosure to this letter.

SNC is ready to support a supplemental inspection in accordance with Inspection Procedure 95001, Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area, the week of December 11, 2023. This was discussed with Mr. Alan Blamey by phone on November 10, 2023.

This letter contains no NRC commitments. If you have any questions, please contact Ryan Joyce, at 205-992-6468.

Respectfully submitted, Jamie Coleman Regulatory Affairs Director JMC/jdj

Enclosure:

Response to Notice of Violation EA-23-080

U. S. Nuclear Regulatory Commission NL-23-0825 Page 2 cc: Regional Administrator, Region ll NRR Project Manager - Farley Nuclear Plant Senior Resident Inspector - Farley Nuclear Plant RTYPE: CFA04.054

References:

1. Joseph M. Farley Nuclear Plant - Integrated Inspection Report (05000348/2023002 and 05000364/2023002 and Apparent Violation, dated August 10, 2023 (EA-23-080)

2. Joseph M. Farley Nuclear Plant - NRC Inspection Report 05000348/2023090 and Preliminary White Finding and Apparent Violation, dated August 31, 2023 (EA 080)

3. Joseph M. Farley Nuclear Plant - Final Significance Determination of a White Finding and Notice of Violation and Assessment Followup Letter - NRC Inspection Report 05000348/2023091), dated October 19, 2023 (EA-23-080)

Joseph M. Farley Nuclear Plant, Unit 1 Reply to Notice of Violation EA-23-080 and Readiness for 95001 Inspection Enclosure Response to Notice of Violation EA-23-080

Enclosure to NL-23-0825 Response to Notice of Violation EA-23-080 E-1 Response to Notice of Violation EA-23-080 Restatement of Violation 05000348/364 - 2023091 During an NRC inspection conducted from April 1 to June 30, 2023, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

x Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XVI, Corrective Action, states, in part, measures shall be established to assure that conditions adverse to quality, such as nonconformance are promptly identified and corrected.

x Technical Specifications (TS) Limiting Condition of Operations (LCO) 3.0.1. requires in part, that LCOs shall be met during the modes of applicability. TS LCO 3.8.1, AC Sources, requires, in part, two operable emergency diesel generator (EDG) sets capable of supplying the onsite Class 1E distribution systems while in Modes 1, 2, 3, or

4.

Contrary to the above, on November 4, 2022, the licensee failed to identify and correct a condition adverse to quality associated with nonconforming work instructions for the installation of a lube oil coupling assembly for the unit 1B EDG following a coupling assembly failure and substantial lube oil leak. In addition, between December 7, 2022, to March 3, 2023, while the plant was in the modes of applicability the 1B EDG was inoperable.

Specifically, the licensee did not adequately disposition the failure via troubleshooting WO SNC 1399361 used to implement corrective actions in accordance with procedure NMP-GM-002-001, Corrective Action Program Instructions, version 43.0. The disposition was inadequate because the licensee failed to adhere to its troubleshooting standards and did not evaluate available evidence surrounding the coupling assembly failure after the immediate cause of the failure could not be identified during implementation of WO SNC1399361. As a result, following the failure on November 4, 2022, repairs to the EDG were limited to replacement of the coupling assembly in accordance with the existing nonconforming work instructions. This resulted in the inoperability of the EDG due to a similar failure on February 26, 2023, during a surveillance run. With the 1B EDG inoperable the licensee failed to meet the LCO in accordance with TS 3.0.1 and 3.8.1 between December 7, 2022, and March 3, 2023.

The violation is associated with a White Significance Determination Process finding. Southern Nuclear Company (SNC) does not contest the violation.

Reason for the Violation SNC does not contest the violation and offers the following discussion regarding the circumstances which resulted in the violation.

On February 26, 2023, the 1B Emergency Diesel Generator (EDG) lube oil pump outlet coupling connection developed an oil leak when the lube oil piping moved and became separated at a flexible coupling location. The root cause was determined to be inadequate piping restraint which allowed the discharge piping to move and subsequently separate from the coupling. In addition, troubleshooting process deficiencies and implementation weaknesses led to the station failing to identify and correct the lube oil system failure mode in November 2022. The

Enclosure to NL-23-0825 Response to Notice of Violation EA-23-080 E-2 root cause analysis concluded that FNP leaders oversight of the 1B EDG circulating lube oil leak evaluation and resolution activities was less than adequate and significantly contributed to this incident.

Corrective Steps Taken and Results Achieved Immediate steps were taken to restore the 1B EDG to operable status by modifying the existing lube oil pipe restraint for the 1B EDG and installing a new additional restraint. Subsequent corrective actions to improve the rigid piping restraints and replace the lube oil pump outlet coupling with hard-piped connections have been implemented for the 1B EDG as well as the other EDGs that have similar piping restraints and coupling connections (specifically, the 1-2A and 2B EDGs). The corrective actions taken have been effective as evidenced by no leakage in the circulating lube oil system.

To address gaps in organizational response, behaviors, and leadership oversight, FNP has revised procedures to clearly define roles, responsibilities and required documentation for issue response, troubleshooting, and corrective actions addressing conditions adverse to quality. The corrective actions of the troubleshooting root cause have been observed to strengthen the organizational responses and behaviors necessary to prevent recurrence.

Corrective Steps to be Taken In addition to effectiveness reviews for the completed corrective actions, FNP will develop and implement a Case Study for this incident. The case study will address multiple departments and levels of management to include responsibilities and documentation requirements of the enhanced troubleshooting and incident response team process. The case study will be completed no later than March 14, 2024.

Additionally, FNP plans to perform teaching and learning sessions to promote alignment and awareness of Maintenance and Engineering personnel and managers for this incidents root cause evaluation including the changes to procedures and necessary behaviors to address gaps in organizational response and oversight by December 2023.

Date When Full Compliance Will Be Achieved Full compliance was achieved on March 3, 2023 when the 1B EDG was restored to operable.