IR 05000348/2021010
| ML21095A017 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 04/05/2021 |
| From: | Alan Blamey NRC/RGN-II/DRP/RPB2 |
| To: | Gayheart C Southern Nuclear Company |
| References | |
| IR 2021010 | |
| Download: ML21095A017 (16) | |
Text
April 5, 2021
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000348/2021010 AND 05000364/2021010
Dear Ms. Gayheart:
On February 26, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Joseph M. Farley Nuclear Plant. On February 26, 2021 the NRC inspectors discussed the results of this inspection with Chuck Kharrl Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
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 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:
Report Numbers:
05000348/2021010 and 05000364/2021010
Enterprise Identifier: I-2021-010-0019
Licensee:
Southern Nuclear Company
Facility:
Joseph M. Farley Nuclear Plant
Location:
Columbia, AL
Inspection Dates:
February 08, 2021 to February 26, 2021
Inspectors:
L. Cooke, Fuel Facility Inspector
D. Mas-Penaranda, Senior Project Engineer, Acting
P. Niebaum, Senior Project Engineer
D. Terry-Ward, Construction Inspector
Approved By:
Alan J. Blamey, Chief
Reactor Projects Branch 2
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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
Pressurizer Safety Valve Lift Pressure Outside of Technical Specifications Limits due to Setpoint Drift Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000364/2021010-01 Open/Closed Not Applicable 71152B A self-revealed Severity Level (SL) IV NCV of Technical Specifications (T.S.) 3.4.10,
Pressurizer Safety Valves, was identified when a routine lift pressure test revealed that the Unit 2 'A' pressurizer safety valve (Q2B13V0031A) as-found set pressure was lower than allowed by T.S. Surveillance Requirement 3.4.10.1 for a duration that exceeded the conditions T.S. required action completion time.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000364/2020-002-00 LER 2020-002-00 for Joseph M. Farley Nuclear Plant Unit 2, Pressurizer Safety Valve Lift Pressure Outside of Technical Specifications Limits due to Setpoint Drift 71152B Closed
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.
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), inspectors were directed to begin teleworking. In addition, 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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program (CAP) Effectiveness: The inspectors assessed the licensee's CAP effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted an in-depth CAP review of the Emergency Diesel Generators, Service Water and Auxiliary Feedwater systems.
- Operating Experience: The inspectors assessed the effectiveness of the licensees processes for the use of operating experience.
- Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensee's self-assessments and audits.
- Safety Conscious Work Environment (SCWE): The inspectors assessed the effectiveness of the licensees programs to establish and maintain a safety conscious work environment.
INSPECTION RESULTS
Assessment 71152B
1. Corrective Action Program Effectiveness
Problem Identification: The inspectors determined that the licensee was effective in identifying problems and entering them into the corrective action program and that there was a low threshold for entering issues into the corrective action program. This conclusion was based on a review of the requirements for initiating condition reports as described in licensee procedure NMP-GM-002, "Corrective Action Program," and managements expectation that employees were encouraged to initiate condition reports. Additionally, site management was actively involved in the corrective action program and focused appropriate attention on significant plant issues.
Problem Prioritization and Evaluation: Based on the review of condition reports, the inspectors concluded that problems were prioritized and evaluated in accordance with the condition report significance determination guidance in procedure NMP-GM-002. The inspectors determined that adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that plant personnel had conducted cause evaluations in compliance with the licensees corrective action program procedures and that cause determinations were appropriate, and considered the significance of the issues being evaluated.
Corrective Actions: Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that corrective actions were mostly timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence. The inspectors reviewed condition reports and effectiveness reviews to verify that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence were sufficient to ensure corrective actions were properly implemented and were effective.
Based on the samples reviewed, the team determined that the licensees corrective action program complied with regulatory requirements and self-imposed standards. The licensees implementation of the corrective action program adequately supported nuclear safety.
2. Operating Experience
The inspectors determined that the station's processes for the use of industry and NRC operating experience information and for the performance of audits and self-assessments were effective and complied with all regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The inspectors concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented to address lessons learned as needed.
3. Self-Assessments and Audits
The inspectors determined that the licensee effectively perform self-assessments and audits to identify issues at a low level, properly evaluated those issues, and resolved them commensurate with their safety significance.
Self-assessments were generally detailed and critical. The inspectors verified that condition reports (CRs) were created to document areas for improvement and findings resulting from self-assessments and verified that actions had been completed consistent with those recommendations. Audits of the quality assurance program appropriately assessed performance and identified areas for improvement. Generally, the licensee performed evaluations that were technically accurate.
4. Safety Conscious Work Environment
Based on interviews with plant staff and reviews of the latest safety culture survey results to assess the safety conscious work environment on site, the inspectors found no evidence of challenges to the safety conscious work environment. Employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
Pressurizer Safety Valve Lift Pressure Outside of Technical Specifications Limits due to Setpoint Drift Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000364/2021010-01 Open/Closed
Not Applicable 71152B A self-revealed Severity Level (SL) IV NCV of Technical Specifications (T.S.) 3.4.10, Pressurizer Safety Valves, was identified when a routine lift pressure test revealed that the Unit 2 'A' pressurizer safety valve (Q2B13V0031A) as-found set pressure was lower than allowed by T.S. Surveillance Requirement 3.4.10.1 for a duration that exceeded the conditions T.S. required action completion time.
Description:
During the Farley Nuclear Plant Unit 2 October 2020 refueling outage, pressurizer safety valve Q2B13V0031A was removed from service and sent to an off-site testing facility. On October 28, 2020, the site was notified that the as-found set pressure was at 2456 psig, which was low outside the plant T.S. allowable lift pressure setting range of 2460 psig to 2510 psig. The valve had been installed and placed in service at Farley Nuclear Plant Unit 2 during the 2017 fall outage and remained in service during three complete 18-month fuel cycles. Pressurizer safety valve Q2B13V0031A from Unit 2 was replaced with a similar operable refurbished valve during the October 2020 refueling outage. Licensee Event Report (LER) 05000364/2020-002-00, Pressurizer Safety Valve Lift Pressure Outside of Technical Specification Limits due to Setpoint Drift, was submitted on December 21, 2020 for this event.
Corrective Actions: The valve was replaced with a similar operable refurbished valve that had been tested satisfactorily prior to its installation in the plant during the refueling outage prior to plant startup. The licensee is pursuing additional corrective actions which include valve spring replacements for all pressurizer safety valves.
Corrective Action References: Condition Report (CR) 10749764
Performance Assessment:
The NRC determined this violation was not reasonably foreseeable and preventable by the licensee and therefore is not a performance deficiency.
Specifically, random setpoint drift is a recognized valid phenomenon that can occur despite routine testing and maintenance.
Enforcement:
Traditional Enforcement is being used to disposition this violation with no associated Reactor Oversight Process performance deficiency per section 3.10 of the Enforcement Manual.
Severity: The inspector assessed the severity of the violation using Section 6.1 of the Enforcement Policy and determined the significance is appropriately characterized as Severity Level IV, due to the inappreciable potential safety consequences. The licensee determined that the safety valve low as-found lift set-point did not have an adverse impact on reactor coolant system over-pressurization protection, since the valve continued to perform its reactor coolant system over-pressure protection function to prevent the system from exceeding the design pressure of 2485 psig. Therefore, the plant remained bounded by the accident analysis in the Final Safety Analysis Report, based on the as-found condition.
Violation: Farley Nuclear Plant unit 2 T.S. LCO 3.4.10, Pressurizer Safety Valves, required three operable pressurizer safety valves with lift settings between 2460 psig and 2510 psig, while the Unit is in modes 1, 2, and 3. With one pressurizer safety valve inoperable, Action Statement, Condition A. Required Action A.1, required restoration of the valve to operable status within 15 minutes. If the required action and associated completion time is not met, Action Statement, Condition B, required that the unit be in mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Contrary to the above, the licensee determined the pressurizer safety valve setting was outside the T.S. limits longer than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 15 minutes during the last three operating cycles, between October 2017 and October 2020, while the Unit was in modes 1 and 2.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Minor Violation 71152B Minor Violation: The team identified one minor violation of 10 CFR Part 50, Appendix B, Criterion XVI Corrective Action, which states in part Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviationsand nonconformance's are promptly identified and corrected. Specifically, site procedure NMP-GM-002-001, Corrective Action Program Instructions, version 40.0 states in part a Corrective ActionEnsures that conditions adverse to quality are promptly identified and corrected. The inspector observed that the instructions in Attachment 2 of NMP-GM-002-001 provides various corrective action methods due date and extension guidance with no maximum number of allowable extension requests to ensure prompt corrections. The licensees failure to promptly correct conditions adverse to quality (CAQ) and work orders (WO) initiated under three
- (3) safety related condition reports (CRs) per site procedure NMP-GM-002-001 was a performance deficiency (PD).
Contrary to this requirement several condition reports CRs which were screened to corrective action reports (CARs) and WOs were identified with specific corrective actions such as correcting deficiencies to safety related calculations and the Final Safety Analysis Report (FSAR) relating to the emergency diesel generator (EDG) air intake, needing a formal analysis/evaluation for the EDGs relating to voltage and frequency, and replacing equipment for the diesel air start system relating to the safety-related to non-safety related boundaries. Specifically, two
- (2) CRs were open in 2016 (CRs 10201380 and CR 10206050)and one
- (1) CR 10206043 opened in 2016 (with issues identified at Farley in 2011) for conditions which required correcting as identified above, however the corrections are currently incomplete.
Screening: The inspectors determined the performance deficiency was minor because although the corrections are incomplete, the following documents; CR 10577000, CR10693471, CAR 266017 and eleven
- (11) work orders are currently in place to perform the corrective actions. The licensee presented documented evidence to the inspectors which demonstrates that the failures to correct had no adverse impact on the EDGs or the EDG air start system.
Enforcement:
This failure to comply with Appendix B, Criterion XVI Corrective Action, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee-initiated CR 10778495 to document the past and current condition.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On February 26, 2021, the inspectors presented the biennial problem identification and resolution inspection results to Chuck Kharrl Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71152B
Corrective Action
Documents
CARs 276759,
276755, 278404,
277843, 276877,
278481, 276976,
277019, 278606,
277171, 275983,
275921, 276128,
276655, 275876,
276523, 276612,
275596, 276145,
276577, 276800,
277026, 276600
CRs 10644961,
10641732,
10744009,
106544744,
10707028,
10749764,
10609393,
10654920,
10658025,
10588757,
10604978,
10624235,
10633466,
10633640,
10636234,
10653756,
10654885,
10655132,
10655489,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
10657055,
10662496,
10663023, 107-
6096, 10708523,
10735066,
10743901,
10749261,
10750965,
10644538,
10670626,
10670635,
10660991,
10672756,
10593185,
10593155,
10594732,
10636199,
10604403,
10600523,
10613474,
10636205,
10617176,
10596093,
10617880,
10599553,
10619203,
10612463,
10599965,
10603790,
10611001,
10582127,
10582227,
10586769,
10629240,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
10634364,
10634455,
10600849,
10604313,
10654581,
10749846,
10751510,
10337680,
10606871,
10629379,
10662410,
10627909
Corrective Action
Documents
Resulting from
Inspection
CR 10774018,
10774019,
10775710,
10775727,
10775732,
10775738,
10775744,
10775944,
10775972,
10777657,
10778495,
10779715,
10779718,
10779723,
10779719,
10779721,
10779722,
10780173.
Engineering
Evaluations
TEs 1051217,
1051669,
1075506,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
1075437,
1063571,
1057041,
1071950,
10749764,
1057166,
1057396,
1057401,
1054623,
1054681,
1068515,
1073314,
1075301,
1075302,
1075429,
1051674,
1057999,
1057997,
1040038,
1040777,
1040772,
1056778,
1038713,
1041784,
1042727,
1046740,
1045204, 987283,
1041166,
1054064,
1077791,
1073161,
1077984,
1036894,
1052636,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
1042312,
1048217
Miscellaneous
Units 1 and 2 Service Water System Health Report
2/01/2020
MREP Meeting #20-03, agenda and minutes
2/26/2020
MR(a)(3) report package August 1, 2018 - December 31,
2019
MREP meeting #20-13, agenda and minutes
11/17/2020
Micro Alara Planning Checklist for SNC1000055, Transport
and Storage of Tri-Nuke Filters from Drumming Room to
SDF
04/04/2019
Micro Alara Planning Checklist for SNC954731, Changeout
and Transport of Tri-Nuc Filters
08/28/2019
Micro Alara Plan for SNC 1079015, Tri-Nuc Filter C/O and
Storage
01/14/2021
PMCR 91408
D204935 Control Penetration EB01 Outside CTMT
D204936 Control Penetration EB01 Inside CTMT
IER L3-19-3R
Plant Farley Radiation Protection Work Plan, U1 and U2 SFP
Tri Nuclear Filter Changeout dated
03/14/2018
Eval-F-P16-
04787
a1 Evaluation for U2 Service Water System
06/18/2019
LDCR 20-008
Revise the FNP Licensing Basis for Tornado Missile
Protection
N11-F02
Maint. Rule Scoping Document for Main Steam System
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
T-92 NWS Test
Procedure,
Spring Data Sheet Rev. 3
11/09/2020
Procedures
MIS-17-032
Unit 2 Fifth 10-Year Interval, Valve Inservice Testing Basis
Document
NMP-ES-027
10.2
NMP-FLS-016-
001
Control of Radiological Diving Operations
3.0
NMP-GM-002
Corrective Action Program
15.2
NMP-GM-002-
001
Corrective Action Program Instructions
NMP-GM-002-
2
Effectiveness Review Instructions
5.3
NMP-GM-029
Equipment Obsolescence Management Process
2.2
OS-BP-001
Operations Performance Indicators
5.1
Work Orders
SNC1122354,
SNC791149,
SNC855711,
SNC1014732,
SNC1033130,
SNC1055920,
SNC1022226,
SNC 1012250,
SNC 1014288,
SNC 1012726,
SNC 1052891