IR 05000348/2020003: Difference between revisions
StriderTol (talk | contribs) (StriderTol Bot insert) |
StriderTol (talk | contribs) (StriderTol Bot change) |
||
(2 intermediate revisions by the same user not shown) | |||
Line 18: | Line 18: | ||
=Text= | =Text= | ||
{{#Wiki_filter: | {{#Wiki_filter:November 4, 2020 | ||
==SUBJECT:== | ==SUBJECT:== | ||
Line 50: | Line 50: | ||
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. | 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 Failure to Adequately Document the Basis for a Change to an Emergency Plan Implementing Procedure Cornerstone Significance Cross-Cutting Report Aspect Section Not Applicable NCV 05000348,05000364/2020003-01 Not Applicable 71114.04 Open/Closed The inspectors identified a SL-IV NCV of Title 10 of the Code of Federal Regulations (CFR), | ===List of Findings and Violations=== | ||
Failure to Adequately Document the Basis for a Change to an Emergency Plan Implementing Procedure Cornerstone Significance Cross-Cutting Report Aspect Section Not Applicable NCV 05000348,05000364/2020003-01 Not Applicable 71114.04 Open/Closed The inspectors identified a SL-IV NCV of Title 10 of the Code of Federal Regulations (CFR), | |||
Part 50.54(q)(3), for changes made to the Farley Nuclear Plant protective action recommendation (PAR) implementing procedure, that failed to demonstrate the changes would not reduce the effectiveness (RIE) of the Emergency Plan (E-Plan). Specifically, the licensee did not provide an adequate analysis for the inspectors to determine that the removal and addition of clarifying information to a risk-significant planning standard implementing procedure was not a RIE of the E-Plan. | Part 50.54(q)(3), for changes made to the Farley Nuclear Plant protective action recommendation (PAR) implementing procedure, that failed to demonstrate the changes would not reduce the effectiveness (RIE) of the Emergency Plan (E-Plan). Specifically, the licensee did not provide an adequate analysis for the inspectors to determine that the removal and addition of clarifying information to a risk-significant planning standard implementing procedure was not a RIE of the E-Plan. | ||
Additional Tracking Items None. | ===Additional Tracking Items=== | ||
None. | |||
=PLANT STATUS= | =PLANT STATUS= | ||
Line 68: | Line 71: | ||
==REACTOR SAFETY== | ==REACTOR SAFETY== | ||
==71111.01 - Adverse Weather Protection Impending Severe Weather Sample (IP Section 03.02)== | ==71111.01 - Adverse Weather Protection== | ||
===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 and potential hurricanes (Laura & | : (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather and potential hurricanes (Laura & | ||
Marco) during the week of August 24, 2020 (FNP-0-AOP-21.0). | Marco) during the week of August 24, 2020 (FNP-0-AOP-21.0). | ||
Line 79: | Line 83: | ||
* Diesel building. | * Diesel building. | ||
==71111.04 - Equipment Alignment | ==71111.04 - Equipment Alignment== | ||
===Partial Walkdown Sample (IP Section 03.01) (3 Samples)=== | |||
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains: | The inspectors evaluated system configurations during partial walkdowns of the following systems/trains: | ||
: (1) Number 1 diesel driven fire pump and motor driven fire pump during the number 2 diesel driven fire pump maintenance outage on July 14, 2020 (Dwg D170366/2). | : (1) Number 1 diesel driven fire pump and motor driven fire pump during the number 2 diesel driven fire pump maintenance outage on July 14, 2020 (Dwg D170366/2). | ||
Line 90: | Line 94: | ||
: (1) The inspectors evaluated system configurations during a complete walkdown of the unit 1 CCW system on September 25 and 26, 2020 (Dwg D175002/1; FNP-1-SOP-023). | : (1) The inspectors evaluated system configurations during a complete walkdown of the unit 1 CCW system on September 25 and 26, 2020 (Dwg D175002/1; FNP-1-SOP-023). | ||
==71111.05 - Fire Protection | ==71111.05 - Fire Protection== | ||
===Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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: | 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: | ||
: (1) Fire Area 044, Fire Zone 0401-U1 for the unit 1 control room during the month of August 2020 (FNP-1-FPP-1.0). | : (1) Fire Area 044, Fire Zone 0401-U1 for the unit 1 control room during the month of August 2020 (FNP-1-FPP-1.0). | ||
Line 99: | Line 103: | ||
: (4) Fire Area 2-021, Fire Zone 2335 for the unit 2 'B' train 4160V switchgear room during the month of August 2020 (FNP-2-FPP-1.0). | : (4) Fire Area 2-021, Fire Zone 2335 for the unit 2 'B' train 4160V switchgear room during the month of August 2020 (FNP-2-FPP-1.0). | ||
==71111.06 - Flood Protection Measures | ==71111.06 - Flood Protection Measures== | ||
===Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)=== | |||
The inspectors evaluated internal flooding mitigation protections in the: | The inspectors evaluated internal flooding mitigation protections in the: | ||
: (1) Unit 2 auxiliary building, 100 foot elevation, auxiliary feedwater pump area on August 12, 2020. (BM-99-1932-001). | : (1) Unit 2 auxiliary building, 100 foot elevation, auxiliary feedwater pump area on August 12, 2020. (BM-99-1932-001). | ||
Line 118: | Line 122: | ||
: (3) 1A/1B/1C charging pump room cooler (Q1E16H001A,-1B,-1C), Section 02.02b. | : (3) 1A/1B/1C charging pump room cooler (Q1E16H001A,-1B,-1C), Section 02.02b. | ||
==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) | ==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) Observed control activities involving I&C maintenance and operator response to alarms on July 27, 2020; a unit 2 'C' charging pump surveillance and a unit 1 'B' emergency diesel generator run on July 29, 2020; unit 2 power operated relief valve block valve testing on August 4, 2020; and operator alarm response and unit 1 'B' emergency diesel generator testing on September 28, 2020. | : (1) Observed control activities involving I&C maintenance and operator response to alarms on July 27, 2020; a unit 2 'C' charging pump surveillance and a unit 1 'B' emergency diesel generator run on July 29, 2020; unit 2 power operated relief valve block valve testing on August 4, 2020; and operator alarm response and unit 1 'B' emergency diesel generator testing on September 28, 2020. | ||
Licensed Operator Requalification Training/Examinations (IP Section 03.02)== | ===Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)=== | ||
: (1) Observed a graded licensed operator continuing training scenario involving a steam generator tube rupture on August 3, 2020 (LOCT 20-5). | |||
: (1) Observed a graded licensed operator continuing training scenario involving a steam generator tube rupture on August 3, 2020 (LOCT 20-5). | |||
==71111.12 - Maintenance Effectiveness | ==71111.12 - Maintenance Effectiveness== | ||
===Maintenance Effectiveness (IP Section 03.01) (2 Samples)=== | |||
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function: | The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function: | ||
: (1) Radiation monitors tracked in accordance with the licensee's maintenance rule program (WO SNC1014723). | : (1) Radiation monitors tracked in accordance with the licensee's maintenance rule program (WO SNC1014723). | ||
: (2) Troubleshooting and repair related to the unit 2 power operated relief valve (PORV 444B) inadvertent opening on July 29, 2020 (CR 10726303). | : (2) Troubleshooting and repair related to the unit 2 power operated relief valve (PORV 444B) inadvertent opening on July 29, 2020 (CR 10726303). | ||
==71111.13 - Maintenance Risk Assessments and Emergent Work Control | ==71111.13 - Maintenance Risk Assessments and Emergent Work Control== | ||
===Risk Assessment and Management Sample (IP Section 03.01) (4 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; | 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 'C' component cooling water heat exchanger outage and 'A' residual heat removal pump testing on July 20, 2020 (NMP-DP-001). | : (1) Unit 2 'C' component cooling water heat exchanger outage and 'A' residual heat removal pump testing on July 20, 2020 (NMP-DP-001). | ||
Line 141: | Line 146: | ||
: (4) Unit 1 risk associated with high voltage switch yard work, testing and calibration of control room instrumentation, and auxiliary feedwater testing on September 9, 2020 (NMP-DP-001). | : (4) Unit 1 risk associated with high voltage switch yard work, testing and calibration of control room instrumentation, and auxiliary feedwater testing on September 9, 2020 (NMP-DP-001). | ||
==71111.15 - Operability Determinations and Functionality Assessments | ==71111.15 - Operability Determinations and Functionality Assessments== | ||
===Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)=== | |||
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments: | The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments: | ||
: (1) Unit 2 main steam valve room temperature concern identified on June 28, 2020 (CR1071863). | : (1) Unit 2 main steam valve room temperature concern identified on June 28, 2020 (CR1071863). | ||
Line 154: | Line 159: | ||
: (6) Turbine driven auxiliary feedwater pump blackout start test (slave relay test) missed surveillance, for both units, identified on September 1, 2020 (CR 10735119). | : (6) Turbine driven auxiliary feedwater pump blackout start test (slave relay test) missed surveillance, for both units, identified on September 1, 2020 (CR 10735119). | ||
==71111.19 - Post-Maintenance Testing | ==71111.19 - Post-Maintenance Testing== | ||
Post-Maintenance Test Sample (IP Section 03.01) === | |||
{{IP sample|IP=IP 10725|count=5}} | |||
The inspectors evaluated the following post maintenance test activities to verify system operability and functionality: | The inspectors evaluated the following post maintenance test activities to verify system operability and functionality: | ||
: (1) Lifting leads in support of of an 'A' train service water recirculation flush on July 13, 2020 (WO SNC1072250). | : (1) Lifting leads in support of of an 'A' train service water recirculation flush on July 13, 2020 (WO SNC1072250). | ||
Line 163: | Line 169: | ||
: (4) Unit 2 'A' train primary room filtration system planned maintenance outage performed on July 21-22, 2020 (WO SNC1011534; SNC1011535). | : (4) Unit 2 'A' train primary room filtration system planned maintenance outage performed on July 21-22, 2020 (WO SNC1011534; SNC1011535). | ||
: (5) Unit 2 'C' charging pump maintenance outage performed July 28-29, 2020 (WO SNC1070382). | : (5) Unit 2 'C' charging pump maintenance outage performed July 28-29, 2020 (WO SNC1070382). | ||
==71111.22 - Surveillance Testing== | |||
The inspectors evaluated the following surveillance tests: | |||
===Surveillance Tests (other) (IP Section 03.01)=== | |||
{{IP sample|IP=IP 71111.22|count=1}} | {{IP sample|IP=IP 71111.22|count=1}} | ||
: (1) Unit 2 reactor coolant pump undervoltage relay testing on June 8, 2020 (FNP-2-STP-912.0). | : (1) Unit 2 reactor coolant pump undervoltage relay testing on June 8, 2020 (FNP-2-STP-912.0). | ||
Inservice Testing (IP Section 03.01) === | ===Inservice Testing (IP Section 03.01) (1 Sample)=== | ||
: (1) Unit 2 turbine auxiliary feedwater pump surveillance on July 6, 2020 (FNP-2-STP- 22.16). | |||
: (1) Unit 2 turbine auxiliary feedwater pump surveillance on July 6, 2020 (FNP-2-STP-22.16). | |||
==71114.02 - Alert and Notification System Testing | ==71114.02 - Alert and Notification System Testing== | ||
== | ===Inspection Review (IP Section 02.01-02.04) (1 Sample)=== | ||
: (1) The inspectors evaluated the maintenance and testing of the alert and notification system during the week of August 24, 2020. | |||
: (1) The inspectors evaluated the | |||
==71114.04 - Emergency Action Level and Emergency Plan Changes Inspection Review (IP Section 02.01-02.03)== | ==71114.03 - Emergency Response Organization Staffing and Augmentation System== | ||
===Inspection Review (IP Section 02.01-02.02) (1 Sample)=== | |||
: (1) The inspectors evaluated the readiness of the Emergency Response Organization during the week of August 24, 2020. | |||
==71114.04 - Emergency Action Level and Emergency Plan Changes== | |||
===Inspection Review (IP Section 02.01-02.03) (1 Sample)=== | |||
: (1) The inspectors evaluated submitted Emergency Action Level, Emergency Plan, and Emergency Plan Implementing Procedure changes during the week of August 24, 2020. This evaluation does not constitute NRC approval. | : (1) The inspectors evaluated submitted Emergency Action Level, Emergency Plan, and Emergency Plan Implementing Procedure changes during the week of August 24, 2020. This evaluation does not constitute NRC approval. | ||
==71114.05 - Maintenance of Emergency Preparedness Inspection Review (IP Section 02.01 - 02.11)== | ==71114.05 - Maintenance of Emergency Preparedness== | ||
: (1) The inspectors evaluated the maintenance of the emergency preparedness program during the week of August 24, 2020. | ===Inspection Review (IP Section 02.01 - 02.11) (1 Sample)=== | ||
: (1) The inspectors evaluated the maintenance of the emergency preparedness program during the week of August 24, 2020. | |||
==71114.06 - Drill Evaluation | ==71114.06 - Drill Evaluation== | ||
===Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)=== | |||
The inspectors evaluated: | The inspectors evaluated: | ||
: (1) A licensed operator continuing training scenario involving a steam generator tube rupture that was credited for drill/exercise performance opportunities on August 3, 2020 (LOCT 20-5). | : (1) A licensed operator continuing training scenario involving a steam generator tube rupture that was credited for drill/exercise performance opportunities on August 3, 2020 (LOCT 20-5). | ||
Line 202: | Line 214: | ||
===EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)=== | ===EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)=== | ||
: (1) EP02: Emergency Response Organization Drill Participation for the period January 1, 2019, through June 30, 2020. | : (1) EP02: Emergency Response Organization Drill Participation for the period January 1, 2019, through June 30, 2020. | ||
EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample) | ===EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)=== | ||
: (1) EP03: Alert & Notification System Reliability for the period January 1, 2019, through June 30, 2020. | : (1) EP03: Alert & Notification System Reliability for the period January 1, 2019, through June 30, 2020. | ||
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (2 Samples) | ===MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (2 Samples)=== | ||
: (1) Unit 1 (July 1, 2019 - June 30, 2020). | : (1) Unit 1 (July 1, 2019 - June 30, 2020). | ||
: (2) Unit 2 (July 1, 2019 - June 30, 2020). | : (2) Unit 2 (July 1, 2019 - June 30, 2020). | ||
Line 219: | Line 231: | ||
: (2) Unit 2 (July 1, 2019 - June 30, 2020). | : (2) Unit 2 (July 1, 2019 - June 30, 2020). | ||
==71152 - Problem Identification and Resolution Semiannual Trend Review (IP Section 02.02)== | ==71152 - Problem Identification and Resolution== | ||
===Semiannual Trend Review (IP Section 02.02) (1 Sample)=== | |||
: (1) The inspectors reviewed the licensees corrective action program for potential adverse trends concerning reliability of the service air compressors from July - | : (1) The inspectors reviewed the licensees corrective action program for potential adverse trends concerning reliability of the service air compressors from July - | ||
August, 2020. This was chosen as the service air supplies instrument air, which is risk significant. A loss of instrument air may cause a significant transient and / or make mitigating an accident condition more difficult (CR10729141). | August, 2020. This was chosen as the service air supplies instrument air, which is risk significant. A loss of instrument air may cause a significant transient and / or make mitigating an accident condition more difficult (CR10729141). | ||
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample) | ===Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)=== | ||
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues: | The inspectors reviewed the licensees implementation of its corrective action program related to the following issues: | ||
: (1) Resolution of equipment issues being monitored via the licensee's Adverse Performance Conditions Monitoring plan as of August 5, 2020. This was chosen to ensure the risk is mitigated appropriatlyappropriately and the issues are resolved in a timely manner commensurate with their significance (NMP-ES-002). | : (1) Resolution of equipment issues being monitored via the licensee's Adverse Performance Conditions Monitoring plan as of August 5, 2020. This was chosen to ensure the risk is mitigated appropriatlyappropriately and the issues are resolved in a timely manner commensurate with their significance (NMP-ES-002). |
Latest revision as of 02:33, 16 April 2021
ML20309A786 | |
Person / Time | |
---|---|
Site: | Farley ![]() |
Issue date: | 11/04/2020 |
From: | Alan Blamey NRC/RGN-II/DRP/RPB2 |
To: | Gayheart C Southern Nuclear Company |
References | |
IR 2020003 | |
Download: ML20309A786 (16) | |
Text
November 4, 2020
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000348/2020003 AND 05000364/2020003
Dear Ms. Gayheart:
On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Joseph M. Farley Nuclear Plant. On October 27, 2020, the NRC inspectors discussed the results of this inspection with Charles Kharrl and other members of your staff.
The results of this inspection are documented in the enclosed report.
One Severity Level IV violation without an associated finding is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
No NRC-identified or self-revealing findings were identified during this inspection.
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:
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,
/RA/
Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 05000348 and 05000364 License Nos. NPF-2 and NPF-8
Enclosure:
As stated
Inspection Report
Docket Numbers: 05000348 and 05000364 License Numbers: NPF-2 and NPF-8 Report Numbers: 05000348/2020003 and 05000364/2020003 Enterprise Identifier: I-2020-003-0048 Licensee: Southern Nuclear Company Facility: Joseph M. Farley Nuclear Plant Location: Columbia, AL Inspection Dates: July 01, 2020 to September 30, 2020 Inspectors: B. Collins, Senior Reactor Inspector D. Mas-Penaranda, Project Engineer P. Meier, Senior Resident Inspector K. Miller, Resident Inspector S. Sanchez, Senior Emergency Preparedness Inspector S. Temple, Resident Inspector J. Viera, Operations Engineer J. Walker, Emergency Response Inspector Approved By: Alan J. Blamey, Chief Reactor Projects Branch 2 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
Failure to Adequately Document the Basis for a Change to an Emergency Plan Implementing Procedure Cornerstone Significance Cross-Cutting Report Aspect Section Not Applicable NCV 05000348,05000364/2020003-01 Not Applicable 71114.04 Open/Closed The inspectors identified a SL-IV NCV of Title 10 of the Code of Federal Regulations (CFR),
Part 50.54(q)(3), for changes made to the Farley Nuclear Plant protective action recommendation (PAR) implementing procedure, that failed to demonstrate the changes would not reduce the effectiveness (RIE) of the Emergency Plan (E-Plan). Specifically, the licensee did not provide an adequate analysis for the inspectors to determine that the removal and addition of clarifying information to a risk-significant planning standard implementing procedure was not a RIE of the E-Plan.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 and unit 2 began the report period at approximately 100 percent rate thermal power (RTP) and remained at or near 100 percent RTP through the end of the report period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.
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 teleworking 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. 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 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.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
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 and potential hurricanes (Laura &
Marco) during the week of August 24, 2020 (FNP-0-AOP-21.0).
External Flooding Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors reviewed that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding for the following areas (FSAR Chapter 2; FNP-0-AOP-21.0):
- Unit 1 and 2 auxiliary buildings
- Unit 1 and 2 containment equipment doors
- Diesel building.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Number 1 diesel driven fire pump and motor driven fire pump during the number 2 diesel driven fire pump maintenance outage on July 14, 2020 (Dwg D170366/2).
- (2) Unit 2 component cooling water (CCW) system during a unit 2 'C' CCW heat exchanger planned maintenance outage and inspection during the week of July 20-25, 2020 (Dwg D205002/1).
- (3) Unit 1 CCW system with the unit 1 'A' CCW pump out of service for planned maintenance activities on August 5, 2020 (Dwg D175002/1).
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the unit 1 CCW system on September 25 and 26, 2020 (Dwg D175002/1; FNP-1-SOP-023).
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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:
- (1) Fire Area 044, Fire Zone 0401-U1 for the unit 1 control room during the month of August 2020 (FNP-1-FPP-1.0).
- (2) Fire Area 044, Fire Zone 0401-U2 for the unit 2 control room during the month of August 2020 (FNP-2-FPP-1.0).
- (3) Fire Area 1-021, Fire Zone 229 for the unit 1 'B' train 4160V switchgear room during the month of August 2020 (FNP-1-FPP-1.0).
- (4) Fire Area 2-021, Fire Zone 2335 for the unit 2 'B' train 4160V switchgear room during the month of August 2020 (FNP-2-FPP-1.0).
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Unit 2 auxiliary building, 100 foot elevation, auxiliary feedwater pump area on August 12, 2020. (BM-99-1932-001).
Cable Degradation (IP Section 03.02) (1 Sample)
The inspectors evaluated cable submergence protection in:
- (1) Pull box 1WB1M54 that included unit 1 'B' train cabling to the unit 1 refueling water storage tank on August 31, 2020 (WO) SNC1083030; NMP-ES-051-004).
71111.07T - Heat Sink Performance Triennial Review (IP Section 03.02)
The inspectors evaluated heat exchanger/sink performance on the following from July 13 -
17, 2020:
- (1) 1A/1B/1C component cooling water heat exchangers (Q1P17H0001A,-1B,-1C),
Section 02.02b.
- (2) 2C emergency diesel generator lube oil/jacket water heat exchangers (QSR43H0503,-0509), Section 02.02b.
- (3) 1A/1B/1C charging pump room cooler (Q1E16H001A,-1B,-1C), Section 02.02b.
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) Observed control activities involving I&C maintenance and operator response to alarms on July 27, 2020; a unit 2 'C' charging pump surveillance and a unit 1 'B' emergency diesel generator run on July 29, 2020; unit 2 power operated relief valve block valve testing on August 4, 2020; and operator alarm response and unit 1 'B' emergency diesel generator testing on September 28, 2020.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) Observed a graded licensed operator continuing training scenario involving a steam generator tube rupture on August 3, 2020 (LOCT 20-5).
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Radiation monitors tracked in accordance with the licensee's maintenance rule program (WO SNC1014723).
- (2) Troubleshooting and repair related to the unit 2 power operated relief valve (PORV 444B) inadvertent opening on July 29, 2020 (CR 10726303).
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 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 'C' component cooling water heat exchanger outage and 'A' residual heat removal pump testing on July 20, 2020 (NMP-DP-001).
- (2) Heavy lift over the unit 1 main turbine on July 2020 in preparation for the unit 2 refueling outage (NMP-DP-001).
- (3) Unit 2 high voltage switchyard work, unit 2 'A' component cooling water heat exchanger outage, and unit 2 'C' charging pump outage on July 29, 2020 (NMP-DP-001).
- (4) Unit 1 risk associated with high voltage switch yard work, testing and calibration of control room instrumentation, and auxiliary feedwater testing on September 9, 2020 (NMP-DP-001).
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 2 main steam valve room temperature concern identified on June 28, 2020 (CR1071863).
- (2) Applicable technical specification action statement associated with the testing of unit 1 residual heat removal to cold leg motor operated valves 8888A and B (FNP-1-STP-10.3, STP-11.1, STP-11.2).
- (3) Vendor identification of calculation errors with the potential to impact Farley's gas void assessment program for the unit 1 and unit 2 emergency core cooling systems and containment spray systems identified on July 9, 2020 (CR 10721258).
- (4) Unit 1 containment thermal element reading high identified on July 27, 2020 (CR
===10725518).
- (5) Unit 1 'C' charging pump oil leak resulting in an inoperable pump identified on August 6, 2020 (CR 10728166).
- (6) Turbine driven auxiliary feedwater pump blackout start test (slave relay test) missed surveillance, for both units, identified on September 1, 2020 (CR 10735119).
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) ===
The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:
- (1) Lifting leads in support of of an 'A' train service water recirculation flush on July 13, 2020 (WO SNC1072250).
- (2) Number 2 diesel driven fire pump maintenance outage on July 14, 2020 (WO SNC435188).
- (3) Unit 2 'C' component cooling water heat exchanger outage and inspection performed during the week of July 20-24, 2020 (WO SNC1037893).
- (4) Unit 2 'A' train primary room filtration system planned maintenance outage performed on July 21-22, 2020 (WO SNC1011534; SNC1011535).
- (5) Unit 2 'C' charging pump maintenance outage performed July 28-29, 2020 (WO SNC1070382).
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Unit 2 reactor coolant pump undervoltage relay testing on June 8, 2020 (FNP-2-STP-912.0).
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) Unit 2 turbine auxiliary feedwater pump surveillance on July 6, 2020 (FNP-2-STP- 22.16).
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the maintenance and testing of the alert and notification system during the week of August 24, 2020.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors evaluated the readiness of the Emergency Response Organization during the week of August 24, 2020.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated submitted Emergency Action Level, Emergency Plan, and Emergency Plan Implementing Procedure changes during the week of August 24, 2020. This evaluation does not constitute NRC approval.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the maintenance of the emergency preparedness program during the week of August 24, 2020.
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) A licensed operator continuing training scenario involving a steam generator tube rupture that was credited for drill/exercise performance opportunities on August 3, 2020 (LOCT 20-5).
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
EP01: Drill/Exercise Performance (IP Section 02.12) ===
- (1) EP01: Drill & Exercise Performance for the period January 1, 2019, through June 30, 2020.
EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)
- (1) EP02: Emergency Response Organization Drill Participation for the period January 1, 2019, through June 30, 2020.
EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)
- (1) EP03: Alert & Notification System Reliability for the period January 1, 2019, through June 30, 2020.
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (2 Samples)
- (1) Unit 1 (July 1, 2019 - June 30, 2020).
- (2) Unit 2 (July 1, 2019 - June 30, 2020).
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)
- (1) Unit 1 (July 1, 2019 - June 30, 2020).
- (2) Unit 2 (July 1, 2019 - June 30, 2020).
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
- (1) Unit 1 (July 1, 2019 - June 30, 2020).
- (2) Unit 2 (July 1, 2019 - June 30, 2020).
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends concerning reliability of the service air compressors from July -
August, 2020. This was chosen as the service air supplies instrument air, which is risk significant. A loss of instrument air may cause a significant transient and / or make mitigating an accident condition more difficult (CR10729141).
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Resolution of equipment issues being monitored via the licensee's Adverse Performance Conditions Monitoring plan as of August 5, 2020. This was chosen to ensure the risk is mitigated appropriatlyappropriately and the issues are resolved in a timely manner commensurate with their significance (NMP-ES-002).
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
41502 - Nuclear Power Plant Simulation Facilities Nuclear Power Plant Simulation Facilities
- (1) The inspector completed inspection of the Unit 1 Plant Reference Simulator (PRS)
"B" in accordance with Inspection Procedure (IP) 41502 "Nuclear Power Plant Simulation Facilities". This effort commenced during the 2nd Quarter Integrated Inspection Report period.
This inspection reviewed simulator physical fidelity with its reference unit to ensure that PRS "B" was sufficiently designed to allow the performance of evolution's prescribed by 10 CFR 55.45 and 55.59.
The inspector reviewed simulator operation during performance of two Initial License Training (ILT) simulator scenarios using IP 41502 criteria for evaluation of plant-reference simulators under 10 CFR 55.46(c) and (d).
INSPECTION RESULTS
Failure to Adequately Document the Basis for a Change to an Emergency Plan Implementing Procedure Cornerstone Severity Cross-Cutting Report Aspect Section Not Severity Level IV Not 71114.04 Applicable NCV 05000348,05000364/2020003-01 Applicable Open/Closed The inspectors identified a SL-IV NCV of Title 10 of the Code of Federal Regulations (CFR),
Part 50.54(q)(3), for changes made to the Farley Nuclear Plant protective action recommendation (PAR) implementing procedure, that failed to demonstrate the changes would not reduce the effectiveness (RIE) of the Emergency Plan (E-Plan). Specifically, the licensee did not provide an adequate analysis for the inspectors to determine that the removal and addition of clarifying information to a risk-significant planning standard implementing procedure was not a RIE of the E-Plan.
Description:
While performing a detailed review of changes to the PAR implementing procedure, the inspectors identified that the licensee removed procedural direction that would have the ERO/dose assessors use actual dose assessment results (as opposed to pre-calculated radiation monitor values) to determine site boundary protective action guidelines during a rapidly progressing radiological event. The change replaced this direction with a statement describing that dose projections were not performed using one-hour release durations, and even though there was a more accurate method of obtaining dose values (via actual measured dose results), the licensee would not use that method.
The inspectors identified in the 50.54(q) change documentation, that the licensee concluded the above changes were editorial in nature and thus, did not necessitate an analysis to determine whether the changes were a RIE of the E-Plan. The inspectors determined that these changes were more than editorial and would require an analysis be performed. Removing direction to perform a dose assessment and use the actual results, without replacing the language with a similar step, contradicts the E-Plan requirement for the emergency response organization (ERO) to recommend necessary actions to offsite authorities from dose assessment. And because the removal of specific ERO direction, and the addition of the clarifying wording, could prevent or delay the ERO from recommending appropriate and necessary protective actions to offsite authorities, the inspectors concluded an analysis was necessary.
Corrective Actions: The licensee entered the issue into the corrective action program on August 28, 2020.
Corrective Action References: Condition Report 10733680
Performance Assessment:
The licensees failure to provide an analysis demonstrating that changes to the PAR implementing procedure was not a reduction in effectiveness and was determined to impede the NRCs ability to perform its regulatory function and is dispositioned using the Traditional Enforcement process.
Enforcement:
Severity: This finding is a violation of NRC requirements because it had the potential for impacting the NRCs ability to perform its regulatory function. Therefore, traditional enforcement is applicable, in accordance with Inspection Manual Chapter 0611 and 0612, Appendix B, Figure 2. This finding is determined to be a SL-IV violation in accordance with Section 6.6.d of the Enforcement Policy because it involves the licensees ability to meet or implement a regulatory requirement not related to assessment or notification such that the effectiveness of the emergency plan is reduced.
Violation:
Title 10 of the Code of Federal Regulations, Part 50.54(q)(3) states, in part, that a licensee may make changes to its emergency plan without NRC approval only if the licensee performs and retains an analysis demonstrating that the changes do not reduce the effectiveness of the plan and the plan, as changed, continues to meet the requirements in Appendix E to this part. Contrary to the above, from August 27, 2019, through August 28, 2020, the licensee failed to perform an analysis demonstrating that changes to their E-Plan, and associated risk-significant planning standard implementing procedure, did not reduce the effectiveness of the Plan. Specifically, the licensee did not provide an analysis to determine whether the addition and removal of specific clarifying wording was not a RIE of the approved Farley E-Plan.
Enforcement Action: This violation is being treated as an 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 October 27, 2020, the inspectors presented the integrated inspection results to Mr.
Charles Kharrl and other members of the licensee staff.
- On August 27, 2020, the inspectors presented the Emergency Preparedness Program Inspection Debrief inspection results to Mr. Charles Kharrl and other members of the licensee staff.
- On July 31, 2020, the inspectors presented the Triennial Heat Sink Performance Inspection Debrief inspection results to Mr. Charles Kharrl, Site Vice President and other members of the licensee staff.
- On July 30, 2020, the inspectors presented the Nuclear Power Plant Simulation Facilities Inspection Debrief inspection results to Mr. Anderson Renaud and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
41502 Corrective Action SDR 24979 Simulator B configuration difference from Main Control Room 7/28/2020
Documents
Resulting from
Inspection
Miscellaneous ILT Scenario FA2020-301 Scenario 1 (Simulator B) 02/10/2020
ILT Scenario FA2020-301 Scenario 2 (Simulator B) 02/10/2020
71111.07T Corrective Action CR10402938 Tracking and Trending of 1B CCW HX Tube Plugging Margin 08/28/17
Documents CR10412548 NRC UHS Inspection: Safety-Related Room Coolers 09/25/17
Maintenance Strategy
CR10619753 Track CCW Plugging Margins 06/13/19
CR10637288 Tracking and Trending of 1B CCW HX Tube Plugging 08/13/19
CR10637290 Tracking and Trending of 1C CCW HX Tube Plugging 08/13/19
CR10656591 Track Margin for CCW Tube Plugging 10/18/19
Engineering 1045860 Track CCW Plugging Margins 6/17/2019
Evaluations 1052259 Required Action from PDI 1-19-04, U1 A Train SW Strainer 9/25/2019
Piping Leak
SNC849982 Flaw Evaluation in 6 HBC-205 Service Water A Train Piping 10/10/17
Miscellaneous N.D.E. Technology Personnel Vision Certification (Wheeler) 7/12/17
NDE Technology, Inc. Personnel Certification Summary 05/01/16
(Wheeler, Eddy Current Technique)
8469 Letter from
- W.G. Hairston, III to
Commission, Joseph
Service Water System Problems Affecting Safety Related
Equipment (NRC Generic Letter 89-13)"
Procedures FNP-0-EMP- Equipment Room Coolers General Inspection Ver. 18.2
213.01
NMP-ES-012 Heat Exchanger Program Ver. 12.0
NMP-ES-012-001 Inspection of Heat Exchangers Ver. 2.0
NMP-ES-012-002 Cleaning of Heat Exchangers Ver. 1.3
NMP-ES-012- Heat Exchanger Program Heat Exchanger Inspection, Testing Ver. 5.0
GL01 and Condition Assessment
NMP-ES-069 Fleet Service Water Program Ver. 3.2
Inspection Type Designation Description or Title Revision or
Procedure Date
NMP-ES-069-001 Fleet Service Water Program Instructions Ver. 3.4
NMP-MA-027 Heat Exchanger Tube Plugging Ver. 3.0
Work Orders SNC1028097 Generate WOs to Perform Tube-Side Inspection and Cleaning Rev. 0
of Unit 1 Safety-Related Room Coolers
71114.04 Corrective Action 10733680 FLT-19-018-01 50.54(q) Contains insufficient Information 08/27/2020
Documents
Resulting from
Inspection
Miscellaneous FLT-19-018-01 NMP-EP-144 - Protective Actions, Version 5, 10 CFR 50.54(q) 08/27/2019
Screening
Procedures STANDARD EMERGENCY PLAN ANNEX for Farley Nuclear Revision 4
Plant, Units 1 and 2
NMP-EP-144 Protective Actions Revision 5
13