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| {{#Wiki_filter:November 10, 2021 | | {{#Wiki_filter: |
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| ==SUBJECT:==
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| JOSEPH M. FARLEY NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000348/2021003, 05000364/2021003, AND 07200042/2021001
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| ==Dear Ms. Gayheart:==
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| On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Joseph M. Farley Nuclear Plant. On October 18, 2021, the NRC inspectors discussed the results of this inspection with Charles Kharrl and other members of your staff.
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| The results of this inspection are documented in the enclosed report.
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| One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
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| If you contest the violation or the significance or 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:
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| 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.
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| 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.
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| Sincerely,
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| /RA/
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| Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 05000348, 05000364, and 07200042 License Nos. NPF-2 and NPF-8
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| ===Enclosure:===
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| As stated
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| ==Inspection Report==
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| Docket Numbers: 05000348, 05000364, and 07200042 License Numbers: NPF-2 and NPF-8 Report Numbers: 05000348/2021003, 05000364/2021003, and 07200042/2021001 Enterprise Identifier: I-2021-003-0009 and I-2021-001-0154 Licensee: Southern Nuclear Company Facility: Joseph M. Farley Nuclear Plant Location: Columbia, AL Inspection Dates: July 01, 2021 to September 30, 2021 Inspectors: D. Bacon, Senior Operations Engineer P. Cooper, Senior Reactor Inspector C. Fontana, Emergency Preparedness Inspector D. Lanyi, Senior Operations Engineer M. Learn, Transportation and Storage Inspector P. Meier, Senior Resident Inspector S. Sanchez, Senior Emergency Preparedness Inspector S. Temple, Resident Inspector J. Walker, Emergency Response Inspector Approved By: Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure
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| 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.
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| List of Findings and Violations Failure to Incorporate Acceptance Criteria for the Spent Fuel Bridge Crane Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 60855 Systems NCV 05000348,05000364/2021003-01 Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the licensee's failure to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to incorporate acceptance criteria for the Spent Fuel Bridge Crane lower runway and upper railway into FNP-0-MP-30.3, Spent Fuel Cask Crane Periodic Mechanical Check, to ensure it can respond to design basis events.
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| Additional Tracking Items Type Issue Number Title Report Section Status URI 05000348,05000364/20 Cask Transfer Operations 60855 Open 21003-02 Outside of the Fuel Handling Building
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| 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.
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| Unit 2 began the report period at approximately 100 percent RTP. On September 14, 2021, power was reduced to approximately 90 percent RTP for turbine valve testing. Subsequently, power was increased back to approximately 100 percent RTP on the same day, September 14, 2021, and remained at or near 100 percent RTP through the end of the report period.
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| 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 standards.
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| 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), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted.
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| As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and 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.
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| REACTOR SAFETY 71111.01 - Adverse Weather Protection External Flooding Sample (IP Section 03.03) (1 Sample)
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| (1) The inspectors reviewed flood protection barriers, mitigation plans, procedures, and equipment to verify they were consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding (FNP-0-AOP-21.0).
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| 71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01) (4 Samples)
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| The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
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| (1) Unit 1 'B' emergency diesel generator with the 'A' air compressor cross-connected to the 'B' air compressor while the 'B' air compressor back pressure valve was inoperable on July 14, 2021 (CR 10812386, FNP-0-SOP-38.0, A181005, D170806)
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| (2) Number 1 diesel driven fire pump and motor driven pump alignment during the Number 2 diesel driven fire pump maintenance outage during the week of August 2, 2021 (Dwg D170366)
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| (3) Unit 2 component cooling water system during the Unit 2 'A' component cooling water pump quarterly test on September 2, 2021 (FNP-2-SOP-023, D205002)
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| (4) Unit 1 'B' motor driven auxiliary system during the Unit 1 'A' motor driven auxiliary system maintenance outage on September 8, 2021 (FNP-1-SOP-22.0, D175007)
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| Complete Walkdown Sample (IP Section 03.02) (1 Sample)
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| (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 component cooling water system on August 26, 2021 (D205002, D205023, FNP-2-SOP-023).
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| 71111.05 - Fire Protection Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
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| 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:
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| (1) 'A' train emergency diesel generator switchgear room (fire zone DGB-56A)
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| on September 22, 2021 (2) 'B' train emergency diesel generator switchgear room (fire zone DGB-56B)
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| on September 22, 2021 (3) Unit 1 turbine building (fire area 1-TB) on September 22, 2021 (4) Control rod drive mechanism room (fire zone 346) on September 23, 2021 (5) Unit 1 'A' motor control center area (fire zone 332) on September 23, 2021 71111.06 - Flood Protection Measures Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
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| The inspectors evaluated internal flooding mitigation protections in the:
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| (1) Unit 1 cable spreading room (calculation BM-99-1932-001, F-RIE-IF-U00-006)
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| 71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
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| (1) Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering
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| requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.
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| Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.
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| Control Room Simulator The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
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| The inspectors completed the inspection sample that was partially completed during the second quarter of 2020 due to pandemic related travel restrictions.
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| 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)
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| 1) The inspectors observed and evaluated licensed operator performance in the control room for the following activities (NMP-OS-007):
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| * Unit 2 dilution and operator response to various control room alarms on August 19, 2021
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| * Unit 1 nuclear instrumentation calibration and testing and operator response to associated alarms on September 9, 2021 Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
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| (1) The inspectors observed and evaluated operator training practice exercise on the simulator involving a reactor trip and large break loss of coolant accident on July 27, 2021.
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| 71111.12 - Maintenance Effectiveness Maintenance Effectiveness (IP Section 03.01) (2 Samples)
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| The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
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| (1) Unit 1 'C' charging pump balancing line leak identified on July 23, 2021 (condition report (CR) 10815070)
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| (2) Unit 2 anticipated transient without scram (ATWS) mitigation system actuation circuitry (AMSAC) system indication issue identified on June 30, 2021 (CR 10719169)
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| 71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
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| 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:
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| (1) Unit 1 'B' residual heat removal pump room cooler out of service for planned maintenance resulting in yellow risk on July 6, 2021 (NMP-DP-001)
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| (2) High voltage switchyard modification work coincident with the Unit 1 'A' residual heat removal pump out of service for planned maintenance on July 13, 2021 (NMP-DP-001; NMP-GM-021)
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| (3) Unit 1 'C' service water 'B' train breaker cubicle work with the 'B' train supplying the in service loads for the turbine building and reactor coolant pumps and the site operating under a conservative system operating conditions due to high summer temperatures on July 28, 2021 (NMP-DP-001)
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| (4) Unit 1 risk with the 2C emergency diesel generator (station blackout generator)
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| unavailable and the 1D load center cooler out of service on August 23, 2021 (NMP-DP-001)
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| 71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
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| The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
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| (1) Unit 1 'B' emergency diesel generator 'B' air receiver low pressure due to issues with the 'B' emergency diesel generator air compressor identified on July 13, 2021 (CR 10812386)
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| (2) Unit 1 turbine driven auxiliary feedwater pump due to issues with the 'A' emergency air compressor identified on July 14, 2021 (CR 10812836)
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| (3) Unit 1 'C' charging pump with a leaking balancing line due to a cracked weld identified on July 23, 2021 (CR 10815070)
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| (4) Unit 2 service water pumps 'C' and 'D' with lower motor bearing oil leaks identified on August 13, 2021 (CRs 10820112 and 10820122)
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| (5) 1-2A emergency diesel generator turbo charger high oil level identified during a 24-hour surveillance run on August 18, 2021 (CR 10821117)
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| (6) Unit 2 'C' steam loop high flow calibration issue identified during a surveillance on August 30, 2021 (CR 10823782)
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| 71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01) (9 Samples)
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| The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
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| (1) 1-2A emergency diesel generator roll-up fire door testing following fusible link installations performed on May 10, 2021 (Work Order (WO) SNC1140375)
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| (2) Unit 1 'B' residual heat removal pump inservice test following system maintenance on July 8, 2021 (WO SNC1135115, FNP-1-STP-11.2)
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| (3) Unit 2 turbine driven auxiliary feedwater system valve test following valve actuator diaphragm replacement on July 8, 2021 (WO SNC1165861, FNP-2-STP-21.3)
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| (4) Number 2 diesel fire pump battery testing following replacement on July 21, 2021 (WO SNC1044166)
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| (5) Number 2 diesel driven fire pump functional test following a planned maintenance outage on August 2 through August 6, 2021 (WO SNC1081516; FNP-0-FSP-203.6)
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| (6) Unit 1 'C' charging pump testing following balancing line weld repair on August 13, 2021 (WO SNC1169344, FNP-1-STP-4.3)
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| (7) Unit 2 'A' component cooling water pump testing following pump control room selector switch replacement on September 2, 2021 (WO SNC1001934)
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| (8) Unit 1 'C' service water pump 'B' electrical train breaker testing following racking mechanism and breaker replacement on September 2, 2021 (WO SNC1153800, FNP-SOP-24.0, FNP-0-SOP-36.6)
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| (9) Unit 2 'B' component cooling water pump testing following valve and pump motor routine maintenance on September 15, 2021 (WO SNC1146235, FNP-2-STP-23.2)
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| 71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests:
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| Surveillance Tests (other) (IP Section 03.01) (3 Samples)
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| (1) Unit 1 'B' charging pump quarterly surveillance on July 30, 2021 (WO SNC1134098, FNP-1-STP-4.2)
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| (2) Unit 2 primary coolant system gross activity determination on September 16, 2021 (FNP-2-STP-741.0, FNP-2-CCP-651.1)
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| (3) Unit 2 main turbine valve testing on September 14, 2021 (FNP-2-STP-62.0)
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| Inservice Testing (IP Section 03.01) (1 Sample)
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| (1) Unit 2 'A' motor driven auxiliary feedwater pump quarterly in-service test on July 21, 2021 (FNP-2-STP-22.1)
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| FLEX Testing (IP Section 03.02) (1 Sample)
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| (1) FLEX diesel generator testing (600V, 480V) on July 26, 2021 (WO SNC1102122, SNC1101732)
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| 71114.01 - Exercise Evaluation Inspection Review (IP Section 02.01-02.11) (1 Sample)
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| (1) The inspectors evaluated the biennial emergency plan exercise during the week of September 20, 2021. The exercise scenario simulated an earthquake that caused multiple alarms in the simulator control room, including a small fuel failure caused by foreign material in the reactor vessel. This met the conditions for declaration of an Unusual Event. A short time later, the 1A startup transformer tripped offline, followed by a turbine generator trip (but no reactor trip, until tripped remotely), along with a trip of the 1-2A emergency diesel generator, the 1B motor driven auxiliary feedwater
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| pump (AFWP), and the turbine driven AFWP. This resulted in a loss of heat sink and met the conditions for declaration of a Site Area Emergency. Lastly, a containment penetration failure created a pathway for a radiological release to the environment and met the conditions for declaration of a General Emergency, which allowed the Offsite Response Organizations to demonstrate their ability to implement emergency actions. This exercise scenario also included a beyond design basis demonstration related to feeding the steam generators from an alternate water supply.
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| 71114.04 - Emergency Action Level and Emergency Plan Changes Inspection Review (IP Section 02.01-02.03) (1 Sample)
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| (1) The inspectors evaluated submitted Emergency Action Level, Emergency Plan, and Emergency Plan Implementing Procedure changes during the week of September 20, 2021. This evaluation does not constitute NRC approval.
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| 71114.08 - Exercise Evaluation Scenario Review Inspection Review (IP Section 02.01 - 02.04) (1 Sample)
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| (1) The inspectors reviewed and evaluated in-office, the proposed scenario for the biennial emergency plan exercise at least 30 days prior to the day of the exercise.
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| OTHER ACTIVITIES - BASELINE 71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
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| MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (2 Samples)
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| (1) Unit 1 (July 1, 2020 through June 30, 2021)
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| (2) Unit 2 (July 1, 2020 through June 30, 2021)
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| BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)
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| (1) Unit 1 (July 1, 2020 through June 30, 2021)
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| (2) Unit 2 (July 1, 2020 through June 30, 2021)
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| BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
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| (1) Unit 1 (July 1, 2020 through June 30, 2021)
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| (2) Unit 2 (July 1, 2020 through June 30, 2021)
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| EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
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| (1) Unit 1 (July 1, 2020 through June 30, 2021)
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| Unit 2 (July 1, 2020 through June 30, 2021)
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| EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
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| (1) Unit 1 (July 1, 2020 through June 30, 2021)
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| Unit 2 (July 1, 2020 through June 30, 2021)
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| EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
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| (1) Unit 1 (July 1, 2020 through June 30, 2021)
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| Unit 2 (July 1, 2020 through June 30, 2021)
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| 71152 - Problem Identification and Resolution Semiannual Trend Review (IP Section 02.02) (1 Sample)
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| (1) The inspectors reviewed the licensees corrective action program for potential adverse trends from August 1, 2019 through July 31, 2021, associated with clappers used in fire protection preaction sprinkler systems designated as high safety significant that might be indicative of a more significant safety issue (CR1078284, 1074662).
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| Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
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| The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
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| (1) Unit 1 'C' service water pump 'B' train breaker racking failures and repairs from April to September 2021. This issue was selected for review due to the multiple racking issues, complicated repairs, and eventual replacement of the racking mechanism.
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| The scope of the review included verification of the licensees repair processes to ensure timely corrective actions were taken and causal evaluations considered equipment degradation (CRs 10790220, 10793414, 10816305).
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| (2) A concern with the in-service testing classification of residual heat removal valves potentially required while in mode 4. The issue was identified by the licensee via industry operating experience and identified on August 26, 2021. This issue was selected based on the safety significance of the residual heat removal system and to review the licensee's response to industry operating experience (CRs 10823116, 10821309).
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| OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 60855 - Operation Of An ISFSI 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) 2690, Inspection Program for Storage of Spent Reactor Fuel and Reactor-Related Greater-than-Class C Waste at Independent Spent Fuel Storage Installations (ISFSI) and for 10 CFR Part 71 Transportation Packaging."
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| Operation Of An ISFSI (1 Sample)
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| (1) Operation of an Independent Spent Fuel Storage Installation From July 19 through July 23, 2021, the inspectors performed a review of the licensees ISFSI activities to verify compliance with regulatory requirements. During the on-site inspection, the inspectors observed and reviewed licensee activities in each of the five safety focus areas including occupational exposure, public exposure, fuel damage, confinement, and impact to plant operations.
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| 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. Additionally, the inspectors performed independent walkdowns of the heavy load lifting equipment and the ISFSI haul path. The inspector also performed an independent radiation survey of the ISFSI pad.
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| INSPECTION RESULTS Failure to Incorporate Acceptance Criteria for the Spent Fuel Bridge Crane Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 60855 Systems NCV 05000348,05000364/2021003-01 Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the licensee's failure to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to incorporate acceptance criteria for the Spent Fuel Bridge Crane lower runway and upper railway into FNP-0-MP-30.3, Spent Fuel Cask Crane Periodic Mechanical Check, to ensure it can respond to design basis events.
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| Description: As described in UFSAR Section 9.1.4.3.2 Spent-Fuel Cask Crane Design Evaluation, the spent-fuel cask crane is a Seismic Category I component and is designed to withstand, without loss of load carrying function, the forces resulting from a safe shutdown earthquake (SSE) when the crane is handling the full-rated load. The crane lower runway and upper railway provide the structural foundation for the spent fuel cask crane to ensure the crane design features will respond as designed to prevent a loss of function.
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| FNP-0-MP-30.3, Spent Fuel Cask Crane Periodic Mechanical Check, is the plant procedure that establishes the periodic (yearly) maintenance checks to be performed on the Spent Fuel Cask Crane. This procedure incorporates acceptance criteria associated with vendor drawings U169215 and U169461 as well as calculation SC-SNC1137180-001. This procedure also satisfies the Technical Requirements Manual (TRS 13.9.5.2) for periodic checks and is credited for managing the aging effects of the crane and its associated components. The inspectors identified two examples where the acceptance criteria were not correctly translated into procedure FNP-0-MP-30.3 Spent Fuel Cask Crane Periodic Maintenance Check.
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| The inspector identified the first example during the review of the licensees design equivalent
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| change package, SNC1137180 Cask Crane Degraded Runway Rail Clip Anchor Bolts. This package modified the lower runway by adding stainless-steel anchor bolts to support the carbon steel bolts that could no longer perform their intended function and to subsequently submerge the rail bolts and clips in a concrete/grout mixture. The modification of the lower runway to include dissimilar metals introduced the potential for galvanic corrosion if the components were to become wet. The inspector identified that the procedure FNP-0-MP-30.3, Spent Fuel Cask Crane Periodic Mechanical Check, did not include acceptance criteria to identify areas of water intrusion to prevent the potential for unmonitored degradation of the lower runway. Additionally, FNP-0-MP-30.3, Spent Fuel Cask Crane Periodic Mechanical Check, also implements the aging management program Overhead and Refueling Crane Inspection Program, (UFSAR Section 18.2.7) which requires the inspection for loss of preload of the spent fuel bridge crane rail clips and bolting. The inspector identified that by submerging the rail clips and bolting in the concrete/grout mixture, the current inspection method to look for loose and missing fasteners would no longer be applicable. As a result, the licensee failed to include an alternative acceptance criteria or alternative inspection method to identify the loss of preload of the lower runway rail clips and bolting.
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| The inspector identified the second example when comparing the as found condition of the upper railway, the spent fuel cask crane design drawings, and the criteria described in procedure FNP-0-MP-30.3, Spent Fuel Cask Crane Periodic Mechanical Check. When reviewing the FNP-0-MP-30.3, Spent Fuel Cask Crane Periodic Mechanical Check, the inspector noted that Step 4.29, Upper Railway, states to check the rail fasteners for proper installation and condition. However, the procedure did not include any acceptance criteria to accomplish this step, such as the minimum required thread engagement. Through interviews with plant personnel, it was noted that skill of the craft was used to identify deficiencies.
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| During a walkdown of the upper railway the inspector identified several crane rail bolts and fasteners had less than 50% thread engagement which was contrary to the design drawings of 100% thread engagement. The licensee reviewed past inspection results and identified that the lack of thread engagement was previously identified and entered into the corrective action program in 2005. However, the deficiency of having approximately 30% of the rail clips and bolting with less than 100% thread engagement had not been evaluated.
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| The inspector concluded that the deficiency had not been subsequently identified by FNP-0-MP-30.3, Spent Fuel Cask Crane Periodic Mechanical Check, due to the lack of acceptance criteria within the procedure. Had the procedure had the specific acceptance criteria, it is the inspectors position that the deficiency would have been identified in the subsequent yearly inspections and would have prevented the crane from being used while in an unanalyzed configuration.
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| Corrective Actions: The licensee performed a preliminary evaluation, assuming a minimum of two threads of engagement, and determined the crane runway and railway could continue to perform its intended function.
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| Corrective Action References: CR 10815116 and CR 10815118 Performance Assessment:
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| Performance Deficiency: The inspector determined that the licensee failure to incorporate acceptance criteria for the Spent Fuel Bridge Crane lower runway and upper railway into FNP-0-MP-30.3, Spent Fuel Cask Crane Periodic Mechanical Check, to ensure it can respond to design basis events was a performance deficiency.
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| Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the failure to identify deficiencies of the rail clip fasteners could compromise the cranes ability to withstand, without loss of load carrying function, the forces resulting from an SSE when the crane is handling the full-rated load.
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| Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspector determined the finding to be of very low safety significance (Green) because it did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety- significant in accordance with the licensees maintenance rule program for greater than 24 hours.
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| Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
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| Enforcement:
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| Violation: 10 CFR Part 50, Appendix B, Criterion III, requires in part that measures shall be established to assure that applicable regulatory requirements and the design basis, are correctly translated into procedures, and instructions.
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| Contrary to the above, the licensee failed to ensure that applicable regulatory requirements and the design basis were correctly translated into specifications, drawings, procedures, and instructions. Specifically, the acceptance criteria that ensures the cranes ability to withstand, without loss of load carrying function, the forces resulting from an SSE when the crane is handling the full-rated load supports was not incorporated for the lower runway and upper railway into inspection procedure FNP-0-MP-30.3 Spent Fuel Cask Crane Periodic Maintenance Check.
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| Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
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| Unresolved Item Cask Transfer Operations Outside of the Fuel Handling 60855 (Open) Building URI 05000348,05000364/2021003-02 Description: The inspectors are reviewing information related to an issue of concern related to 10 CFR 72.48 associated with the licensees decision to mitigate the potential for tornado missiles from striking an MPC in a HI-STORM with the HI-STORM lid removed, through a combination of administrative controls rather than design against the effects of natural phenomena as required by 10 CFR 72.122 (b)(6).
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| 10 CFR 72.212 (b)(6), states that the general licensee must, review the Safety Analysis Report referenced in the Certificate of Compliance (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 inspectors reviewed the Joseph M. Farley Nuclear Plant Independent Spent Fuel Storage Installation, 10 CFR 72.212 Report, (72.212 report) and identified that in section 7.2.c
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| Tornados, the licensee states that ...the multi-purpose canister (MPC) transfer operations are performed in the east alleyway behind the auxiliary building using equipment governed by the requirements of Part 50. Additionally, the 72.212 report states ...to minimize the potential for a tornado missile to impact the HI-TRAC 125 or HI-STORM 100 during MPC transfer operations, a loaded HI-TRAC 125 transfer cask will not be moved outside the FNP auxiliary building during inclement weather. The inspectors identified that since this operation is performed outside the fuel handling building, the HI-STORM and MPC within the HI-STORM is subject to natural phenomena, such as tornados.
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| Additionally, during transfer operation with the MPC lid removed, the inspector identified that the HI-STORM is in a configuration that is different than that discussed in the HI-STORM 100 Safety Analysis Report, HI-2002444 (HI-STORM FSAR), Section 11.2.6.2 Tornado Analysis, and Section 3.1.4.8 Tornado Missile Evaluation. The inspectors noted that NUREG-2215, Section 4.5.3.3.3, states that, the NRC does not accept the presumption that there will be sufficient warning of tornadoes so that operations, such as transfer between the fuel transfer facility and storage site, may never be exposed to tornado effects.
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| This unresolved item is being opened, as it relates to the licensees approach to use administrative controls in lieu of performing a deterministic evaluation, to determine if:
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| * the licensee has adequately reviewed the Safety Analysis Report referenced in the CoC or amended CoC and the related NRC Safety Evaluation Report, to determine whether or not the reactor site parameters, including analyses of tornado missiles, are enveloped by the cask design bases considered in these reports.
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| * the licensee is in compliance with 10 CFR 72.48.
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| * other onsite ISFSI operations utilize a similar approach to evaluation.
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| Planned Closure Actions: Region II will coordinate with the Division of Fuel Management in the NRC Office of Nuclear Materials Safety and Safeguards and with the licensee to discuss and evaluate additional information.
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| EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
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| * On September 23, 2021, the inspectors presented the Emergency Preparedness Exercise Inspection results to Mr. D. Erb and other members of the licensee staff.
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| * On October 18, 2021, the inspectors presented the integrated inspection results to Mr.
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| Charles Kharrl and other members of the licensee staff.
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