IR 05000348/2021011
| ML21347A401 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/13/2021 |
| From: | James Baptist NRC/RGN-II/DRS/EB1 |
| To: | Gayheart C Southern Nuclear Operating Co |
| References | |
| IR 2021011 | |
| Download: ML21347A401 (12) | |
Text
December 13, 2021
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT - DESIGN BASIS ASSURANCE INSPECTION (PROGRAMS) INSPECTION REPORT 05000348/2021011 AND 05000364/2021011
Dear Ms. Gayheart:
On November 16, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Joseph M. Farley Nuclear Plant and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
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.
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/
James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety 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: 05000348/2021011 and 05000364/2021011 Enterprise Identifier: I-2021-011-0024 Licensee: Southern Company Nuclear Facility: Joseph M. Farley Nuclear Plant Location: Columbia, AL Inspection Dates: October 18, 2021 to November 05, 2021 Inspectors: C. Baron, Contractor P. Carman, Senior Reactor Inspector R. Patterson, Senior Reactor Inspector Approved By: James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (programs) 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 Properly Categorize MOVs 8809A & B or Check Valve Q1(2)E11V0028 in the IST Program Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21N.
Systems NCV 05000348,05000364/2021011-01 02 Open/Closed The inspectors identified a Green NCV of 10 CFR 50.55a(f), Inservice Testing Requirements, subsection (4) for the licensees failure to categorize any Unit 1 & 2 RHR pump suction isolation valves (MOVs 8809A & B or check valve Q1(2)E11V0028) as inservice test (IST) Class A for which seat leakage is limited to a specific maximum amount in the closed position. Specifically, the licensees inservice testing program did not test safety-related valves in accordance with, ASME OM code Subsection ISTC-1300, Valve Categories, to ensure they could meet seat leakage requirements.
Additional Tracking Items
None.
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.
REACTOR SAFETY
71111.21N.02 - Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements POV Review (IP Section 03)
The inspectors:
a. Determined whether the sampled POVs are being tested and maintained in accordance with NRC regulations along with the licensees commitments and/or licensing bases.
Specific Guidance b. Determined whether the sampled POVs are capable of performing their design-basis functions.
c. Determined whether testing of the sampled POVs is adequate to demonstrate the capability of the POVs to perform their safety functions under design-basis conditions.
d. Evaluate maintenance activities including a walkdown of the sampled POVs (if accessible).
- (1) Q2E21MOV8108, Chemical and Volume Control System (CVCS) Charging Pump Discharge to Regenerative Heat Exchange (HX)
- (2) Q2N11PV3371A, Main Steam Line Atmospheric Vent Valve
- (3) Q2N23MOV3209A, Motor Driven Auxiliary Feedwater (MDAFW) Pump Service Water (SW) Inlet
- (4) Q1N12HV3226, Main Steam to Turbine Driven Auxiliary Feedwater Pump
- (6) Q2E11MOV8889, Residual Heat Removal (RHR) HX Discharge to Reactor Coolant System (RCS) Hot Leg
INSPECTION RESULTS
Failure to Properly Categorize MOVs 8809A & B or Check Valve Q1(2)E11V0028 in the IST Program Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21N.0 Systems NCV 05000348,05000364/2021011-01 2 Open/Closed The inspectors identified a Green NCV of 10 CFR 50.55a(f), Inservice Testing Requirements, subsection
- (4) for the licensees failure to categorize any Unit 1 & 2 RHR pump suction isolation valves (MOVs 8809A & B or check valve Q1(2)E11V0028) as inservice test (IST) Class A for which seat leakage is limited to a specific maximum amount in the closed position. Specifically, the licensees inservice testing program did not test safety-related valves in accordance with, ASME OM code Subsection ISTC-1300, Valve Categories, to ensure they could meet seat leakage requirements.
Description:
The inspectors noted that a refueling water storage tank (RWST) leakage inflow rate of 3.5 gallons per minute (gpm) was assumed in final safety analysis report (FSAR)
Table 15.4-14, Parameter Used in the Loss of Coolant Accident (LOCA) analysis and that the other potential leakage paths from the emergency core cooling system (ECCS) to the vented RWST included valves that were subject to leak testing. The inspectors also noted that calculation BM-98-1711-001, Reverse Flow Evaluation of RWST Check Valves, revision 2 (approved on October 24, 2001) determined that the post-accident containment pressure could be approximately 8 psid greater than the RWST static head at the time of ECCS recirculation transfer. However, this potential leakage path from the ECCS to the RWST did not include any isolation valves that were subject to leak testing to ensure that the 3.5 gpm leakage parameter assumed in the site boundary and control room radiation dose analyses would not be exceeded.
The NRC issued Information Notice (IN) 91-56, Potential Radioactive Leakage to Tank Vented to Atmosphere, alerting licensees to potential problems resulting from the leakage of isolation valves in ECCS recirculation lines to the RWST, which is vented to the atmosphere.
The NRC informed licensees of corrective actions that could address the leak path vulnerabilities, by incorporating the valves identified in the leak path into the inservice testing program and categorizing them as Category A valves. The NRC noted 10 CFR 50.55a, which references the ASME OM Code, and subsection ISTC- 1300 Valve Categories stipulates that Category A valves are valves for which seat leakage is limited to a specific maximum amount in the closed position for fulfillment of their required functions. The inspectors determined the licensee did not leak test MOVs 8809A & B or check valve Q1(2)E11V0028, to assure that following a design basis accident, during ECCS recirculation, the leakage of containment sump water to the RWST is maintained within the values assumed in the calculation of site boundary and control room doses. The licensee entered the issue into their CAP as CR 10840257 on November 9, 2021.
Corrective Actions: The licensee entered the issue into their CAP as CR 10840257 on November 9, 2021. The licensee provided additional information supporting the operability and functionality of MOVs 8809A & B or check valve Q1(2)E11V0028 to prevent excessive backflow from the containment sump to the RWST. Specifically, MOVs 8809A & B are required to be closed prior to opening the associated containment sump isolation valves and check valve Q1(2)E11V0028 has been periodically tested to verify its reverse flow closure.
Performance Assessment:
Performance Deficiency: The failure of the licensee to properly categorize MOVs 8809A & B or check valve Q1(2)E11V0028 in their inservice testing program to ensure they could perform their safety function was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Specifically, the finding was a deficiency affecting the design of a mitigating SSC, and the SSC did maintain its operability and functionality.
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.
Enforcement:
Violation: Title 10 CFR 50.55a(f), Inservice testing requirements, subsection
- (4) requires in part, that pumps and valves which are classified as ASME Class 1, Class 2, and Class 3 must meet the inservice test requirements set forth in the ASME OM Code and addenda that become effective subsequent to editions and addenda specified in paragraphs (f)(2) of this section and that are incorporated by reference in paragraph (a)(1)(iv) of this section.
Furthermore, subsection (f)(4)(ii) requires, inservice tests to verify operational readiness of pumps and valves, whose function is required for safety, conducted during successive 120-month intervals must comply with the requirements of the latest edition and addenda of the ASME OM Code incorporated by reference in paragraph (a)(1)(iv) of this section 18 months before the start of the 120-month interval. The ASME Code of record for Farley for Operation and Maintenance of Nuclear Power Plants (OM) is the 2004 Edition with Addenda through OMb-2006. Subsection ISTC- 1300, Valve Categories, requires in part, that valves within this subsection shall be placed in one or more of the following categories. Category A is for valves for which the seat leakage is limited to a specific maximum amount in the closed position for fulfillment of their required function(s), as specified in ISTA-1100.
Contrary to the above, since 2001, the licensee did not categorize MOVs 8809A & B or check valve Q1(2)E11V0028 as Category A valves to ensure the ASME OM test requirements were met by leak testing the valves to ensure the dose remains within control room and site boundary limits during a design basis accident. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy. The violation was entered into the licensees CAP as CR 10840257. (NCV 05000348, 364/2021011-01 Failure to Properly Categorize MOVs 8809A & B or Check Valve Q1(2)E11V0028 in the IST Program)
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On November 16, 2021, the inspectors presented the design basis assurance inspection (programs) inspection results to Cheryl Gayheart and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.21N.02 Calculations BM-98-1711-001 Reverse Flow Evaluation of RWST Check Valves Rev. 2
71111.21N.02 Calculations F-RIE-IEIF- Farley Farley Nuclear Plant Units 1 and 2 Risk Ranking for Version 1
MOVR-RNK Motor-Operated and Air-Operated Valves (Following Rev. 9
Version 3 Model update)
71111.21N.02 Calculations F-RIE- Farley Unit 1 and 2 Valve Risk Ranking Evaluation Version 1
VALVERISK-U00
71111.21N.02 Calculations FNP- Thrust and Torque Calculation Rev. 2
Q1E21MOV8803B
71111.21N.02 Calculations FNP- Thrust and Torque Calculation Rev. 2
Q1N23MOV3209A
71111.21N.02 Calculations FNP- Thrust and Torque Calculation Rev. 1
Q2E11MOV8887A
71111.21N.02 Calculations FNP- Thrust and Torque Calculation Rev. 1
Q2E11MOV8889
71111.21N.02 Calculations SE-91-1925-14- MOV 3232A,B,C: Terminal Voltage at End of Stroke Rev. 1
71111.21N.02 Calculations SE-94-0-0378-001 MOV Combination Starter Component Sizes and Settings Rev. 5
71111.21N.02 Calculations SE-94-0470-001 Unit 1 As-Built Load Study Rev. 10
71111.21N.02 Calculations SE-SNC529029- Unit 1 Minimum Expected Voltage Study Rev. 2
001
71111.21N.02 Calculations SM-04-4801-002 AOV Design Basis Review - Setpoints for Q1N12HV3226 Version 2.0
71111.21N.02 Calculations SM-90-1653-001 MOV Thrust Requirements for Gate & Globe Valves Version 17
71111.21N.02 Calculations SM-90-1653-002 Reduced Voltage Torque/Thrust Capability for Gate & Version 23
Globe Valves in the FNP MOV Program
71111.21N.02 Calculations SM-90-1653-002 Reduced Voltage Torque/Thrust Capability for Gate & Rev. 23
Globe Valves in the FNP MOV Program
71111.21N.02 Calculations SM-90-1653-003 Design Basis Differential Pressure for the MOV Program Rev. 15
71111.21N.02 Calculations SM-90-1653-003 Design Basis Differential Pressure for the MOV Program Version 15
71111.21N.02 Calculations SM-99-2189-007 AOV Design Basis Review - Setpoints for Version 2
Q2N11PV3371A/B/C
71111.21N.02 Corrective Action 10835846 Discrepancy Between the Values for Required Voltage for 10/20/2021
Documents MOV8803B
Inspection Type Designation Description or Title Revision or
Procedure Date
Resulting from
Inspection
71111.21N.02 Corrective Action 10837853 Revision Requested for NMP-ES-017-008 10/29/2021
Documents
Resulting from
Inspection
71111.21N.02 Corrective Action 10840257 Maximum Allowable Leakage from the Containment Sump 11/09/2021
Documents to RWST
Resulting from
Inspection
71111.21N.02 Corrective Action 10840275 Incorrect Test Methodology for Category A/C Check Valves 11/09/2021
Documents
Resulting from
Inspection
71111.21N.02 Corrective Action CR 10835850 10835850 - Discrepancy in the Electrical Inspection 10/20/2021
Documents Procedure
Resulting from
Inspection
71111.21N.02 Drawings D-175033 Main Steam and Auxiliary Steam Systems Version 12
71111.21N.02 Drawings D-175038 Sht. 1, P&ID - Safety Injection System Rev. 44
71111.21N.02 Drawings D-205007 P&ID - Auxiliary Feedwater System, Sheet 1 Version 29.0
71111.21N.02 Drawings D-205033 P&ID - Main Steam and Auxiliary Steam System, Sheet 1 Version 43.0
71111.21N.02 Drawings D-205038 Sht. 1, P&ID - Safety Injection System Rev. 39.0
71111.21N.02 Drawings D-205038 Sht. 2, P&ID - Safety Injection System Rev. 24.0
71111.21N.02 Drawings D-205039 P&ID Chemical and Volume Control System, Sheet 6 Version 11.0
71111.21N.02 Drawings U-176883 Outline & Dimensions for HV-3226 Version 2.0
71111.21N.02 Drawings U-205093 8 150# OSY Gate Valve 11/25/1975
71111.21N.02 Drawings U-277627 Atmosphere Relief Valve Version 13.0
71111.21N.02 Drawings U-611878 3 1500# Bolted Bonnet Gate Valve Q2E21MOV8106, Version 1.0
Q2E21MOV8107, & Q2E21MOV8108 (V265, V257, &
V258)
71111.21N.02 Miscellaneous ALA-10-147 Summary of Seismic and Weak Link Calculation Performed 11/18/2020
for Valves at Locations 8106, 8107 and 8108
71111.21N.02 Miscellaneous ALA-11-89 Increase of Weak Link Closing Trust for Farley Units 1 and 10/27/2011
Inspection Type Designation Description or Title Revision or
Procedure Date
Valve Locations 8106, 8107, and 8108
71111.21N.02 Miscellaneous LDCR 20-044 Removal of Containment Penetrations 23, 24, 28, 42, 43, Version 1.0
44, 45, 46, 61a, 61b, 66 and 67 from the Requirements of
Technical Specification 5.5.17, Containment Leakage Test
Program
71111.21N.02 Procedures FNP-1-EEP-1 Loss of Reactor or Secondary Coolant Rev. 35.0
71111.21N.02 Procedures FNP-1-ESP-1.2 Post LOCA Cooldown and Depressurization Rev. 26.0
71111.21N.02 Procedures FNP-1-ESP-1.3 Transfer to Cold Leg Recirculation Rev. 25.0
71111.21N.02 Procedures FNP-1-ESP-1.4 Transfer to Simultaneous Cold and Hot Leg Recirculation Rev. 16.0
71111.21N.02 Procedures FNP-1-SOP-7.0 Residual Heat Removal System Rev. 112.0
71111.21N.02 Procedures FNP-1-STP-11.17 RHR RWST Suction Check Valve Reverse Closure Test 10/09/19
71111.21N.02 Procedures FNP-1-STP-21.3 TDAFWP Steam Supply Valve IST 06/28/2021
71111.21N.02 Procedures FNP-1-STP-4.10 Reverse Flow Testing of RWST to Charging Pump Check Rev. 22.0
Valve & CVCS Emerg. Borate Filter to Chg. Pmp. Suction
71111.21N.02 Procedures FNP-1-STP-40.0B Safety Injection with Loss of Off-Site Power Test - B Train Rev. 12.0
71111.21N.02 Procedures FNP-1-STP-45.4 ECCS Refueling Outage Valves Inservice Test 04/09/21
71111.21N.02 Procedures FNP-1-UOP-1.1 Startup of Unit from Cold Shutdown to Hot Standby Rev. 110.2
71111.21N.02 Procedures FNP-1-UOP-1.2 Startup of Unit from Hot Standby to Minimum Load Rev. 120.0
71111.21N.02 Procedures FNP-2-SOP-7.0 Residual Heat Removal System Rev. 102.0
71111.21N.02 Procedures FNP-2-STP-11.17 RHR RWST Suction Check Valve Reverse Closure Test 10/23/20
71111.21N.02 Procedures FNP-2-STP-11.6 Residual Heat Removal Valves Inservice Test 11/02/20
71111.21N.02 Procedures FNP-2-STP-11.6 Residual Heat Removal Valves Inservice Test 07/26/21
71111.21N.02 Procedures FNP-2-STP-158.0 Reactor Coolant System Pressure Isolation Valve Leak 11/10/20
Test
71111.21N.02 Procedures FPN-0-SOP-103.0 Return to Service Checklist and Return to Service Systems Rev. 49.0
Lineup
71111.21N.02 Procedures NMP-ES-017 Motor-Operated Valve Program Version 10.1
71111.21N.02 Procedures NMP-ES-017-001 Motor Operated Valve (MOV) Regulatory Scoping Process Version 6.2
71111.21N.02 Procedures NMP-ES-017-001- FNP GL89-10/96-05 MOV Program Scope Version 1.0
F-V3
71111.21N.02 Procedures NMP-ES-017-002 Motor Operated Valve Design Basis Setpoint Deamination Version 6.2
71111.21N.02 Procedures NMP-ES-017-003 Motor Operated Valve Performance Trending and Margin Version 5.2
Inspection Type Designation Description or Title Revision or
Procedure Date
Management
71111.21N.02 Work Orders SNC75202,
SNC390935,
SNC679107,
SNC681216,
SNC681217,
SNC831498,
SNC835825,
SNC835825,
SNC975098
9