ML111590912
| ML111590912 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 06/08/2011 |
| From: | Croteau R Division Reactor Projects II |
| To: | Stinson L Southern Nuclear Operating Co |
| References | |
| EA-11-112 IR-11-012 | |
| Download: ML111590912 (13) | |
See also: IR 05000348/2011012
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200
ATLANTA, GEORGIA 30303-1257
June 8, 2011
Mr. L. Michael Stinson
Vice President - Farley
Southern Nuclear Operating Company, Inc.
7388 North State Highway 95
Columbia, AL 36319
SUBJECT: JOSEPH M. FARLEY NUCLEAR PLANT, NRC INSPECTION REPORT
05000348/2011-012 AND 05000364/2011-012 AND PRELIMINARY WHITE
FINDING
Dear Mr. Stinson:
This letter transmits a finding for the Joseph M. Farley Nuclear Plant, Unit 2, which has
preliminarily been determined to be White, i.e., a finding with low to moderate increased safety
significance that may require additional NRC inspections. As described in the enclosed
inspection report, the finding involves the failure to maintain the configuration of the 1A RCP oil
lift pump system in accordance with plant design and drawings. This resulted in an electrical
short on November 10, 2010, that caused a fire on the Unit 1 main control room (MCR) 1A
reactor coolant pump (RCP) board handswitch. The finding affected both units due to the
common control room. For Unit 1, the risk was preliminarily determined to be of very low safety
significance (Green), since that unit was shut down at the time. However, the predominant risk
factor for the event was associated with Unit 2 since it was operating at the time. Final
disposition of the issue for Unit 1 will be made in conjunction with the final significance
determination for Unit 2. NRC Inspection Report Number 05000348, 364/2010005 (ADAMS
Accession Number ML110280059), dated January 27, 2011, provides additional details
regarding the staffs review of this matter. Subsequent in-office and on-site inspections were
completed on May 24, 2011, as documented in the enclosed inspection report. This issue was
discussed on June 8, 2011, with Mr. T. Youngblood and other members of your staff.
This finding was assessed based on the best available information, including appropriate
assumptions, using the applicable Significance Determination Process (SDP). The NRC took
into consideration the testing that your staff performed to recreate the fire conditions when
performing the risk assessment. The finding was preliminarily determined to be of low to
moderate safety significance (White) for Unit 2. The final resolution of this finding will convey
Enclosure(s) transmitted herewith contains(s) SUNSI. When separated from enclosure(s)
this transmittal document is decontrolled.
LIMITED INTERNAL
DISTRIBUTION PERMITTED
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SNC 2
the increment in the importance to safety by assigning the corresponding color, i.e., White, a
finding with low to moderate increased importance to safety that may require additional NRC
inspections. The fire event, caused by the mis-wiring of the 1A RCP oil lift pump pressure
switch, was considered to be potentially challenging (i.e. if not suppressed, the fire could have
eventually led to a MCR evacuation). The basis for assuming the fire could be potentially
challenging was based upon the subjective classification criteria of NUREG-6850, Fire PRA
Methodology for Nuclear Power Plants, Appendix C, Section C.2.3.2, Subjective Classification
Criteria. Specifically, this was considered to be a fire requiring active intervention to prevent
spread. The SDP analysis is included as Enclosure 2. Although the Unit 2 finding has potential
safety significance, it does not present an immediate safety concern because you implemented
corrective actions that included, but were not limited to, correcting the mis-wiring on the 1A RCP
oil lift pump pressure switch and replacing the damaged 1A RCP handswitch on the MCR
board.
The finding is also an apparent violation of Technical Specification 5.4.1 as discussed in the
enclosed inspection report, and is being considered for escalated enforcement action in
accordance with the Enforcement Policy, which can be found on the NRCs Web site at
http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. In addition, this finding is
considered to have a cross-cutting aspect related to the Work Practices component of the
Human Performance area in that personnel proceeded with work despite uncertainty and
unexpected circumstances H.4(a).
In accordance with NRC Inspection Manual Chapter (IMC) 0609, Significance Determination
Process, we intend to complete our risk evaluations using the best available information and
issue our final determination of safety significance within 90 days of this letter. The SDP
encourages an open dialogue between the staff and the licensee; however, the dialogue should
not impact the timeliness of the staffs final determination. Before we make a final decision on
this matter, we are providing you with an opportunity to (1) attend a Regulatory Conference
where you can present to the NRC your perspective on the facts and assumptions the NRC
used to arrive at the finding and assess its significance, or (2) submit your position on the
finding to the NRC in writing. If you request a Regulatory Conference, it should be held within
30 days of the receipt of this letter and we encourage you to submit supporting documentation
at least one week prior to the conference in an effort to make the conference more efficient and
effective. If a Regulatory Conference is held, it will be open for public observation. If you
decide to submit only a written response, such submittal should be sent to the NRC within 30
days of your receipt of this letter. If you decline to request a Regulatory Conference or submit a
written response, you relinquish your right to appeal the final SDP determination, in that by not
doing either, you fail to meet the appeal requirements stated in the Prerequisite and Limitation
sections of Attachment 2 of IMC 0609.
Please contact Mr. Scott Shaeffer at (404) 997-4521 within 10 business days from the issue
date of this letter to notify the NRC of your intentions. If we have not heard from you within 10
business days, we will continue with our significance determination and enforcement decision.
The final resolution of this matter will be conveyed in separate correspondence.
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SNC 3
Since the NRC has not made a final determination in this matter, no Notice of Violation is being
issued for this inspection finding at this time. In addition, please be advised that the number
and characterization of the apparent violation may change as a result of further NRC review.
Additionally, if you disagree with the cross-cutting aspect assigned to the finding in this report,
you should provide a response within 30 days of the date of this inspection report, with the basis
for your disagreement, to the Regional Administrator, Region II, and the NRC Resident
Inspector at the Joseph M. Farley Nuclear Plant.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,
Enclosure 1, and your response (if you choose to provide one), will be made available
electronically for public inspection in the NRC Public Document Room or from ADAMS,
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. However,
because of the security-related information contained in Enclosure 2, and in accordance with 10 CFR 2.390, a copy of Enclosure 2 will not be available for public inspection. To the extent
possible, your response should not include any personal privacy, proprietary, or safeguards
information so that it can be made available to the Public without redaction.
Sincerely,
/RA/
Richard P. Croteau, Director
Division of Reactor Projects
Docket No.: 50-348, 50-364
Enclosure(s): 1. NRC Inspection Report 05000348/2011012, 05000364/2011012
2. SDP Phase 3 Summary (OFFICIAL USE ONLY - SECURITY RELATED
INFORMATION)
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______ML111590912________
OFFICE RII:DRP RII:DRP RII:DRP RII:DRS RII:EICS RII:DRP
SIGNATURE SDR /RA/ Via email Via email Vai email Via email SMS /RA/
NAME SRose ECrowe JSowa WRogers CEvans SShaeffer
DATE 06/08/2011 06/08/2011 06/08/2011 06/08/2011 06/08/2011 06/07/2011
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
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SNC 4
cc w/encl: J. L. Pemberton
B. D. McKinney, Jr. SVP & General Counsel-Ops & SNC
Regulatory Response Manager Southern Nuclear Operating Company, Inc.
Southern Nuclear Operating Company, Inc. Electronic Mail Distribution
Electronic Mail Distribution
Chris Clark
M. J. Ajluni Commissioner
Nuclear Licensing Director Georgia Department of Natural Resources
Southern Nuclear Operating Company, Inc. Electronic Mail Distribution
Electronic Mail Distribution
John G. Horn
T. D. Honeycutt Site Support Manager
Regulatory Response Supervisor Joseph M. Farley Nuclear Plant
Southern Nuclear Operating Company, Inc. Southern Nuclear Operating Company, Inc.
Electronic Mail Distribution Electronic Mail Distribution
Todd L. Youngblood Ted V. Jackson
Plant Manager Emergency Response and Radiation
Joseph M. Farley Nuclear Plant Program Manager
Electronic Mail Distribution Environmental Protection Division
Georgia Department of Natural Resources
L. P. Hill Electronic Mail Distribution
Licensing Supervisor
Southern Nuclear Operating Company, Inc. Tom W. Pelham
Electronic Mail Distribution Performance Improvement Supervisor
Joseph M. Farley Nuclear Plant
Jeffrey T. Gasser Southern Nuclear Operating Company, Inc.
Chief Nuclear Officer Electronic Mail Distribution
Southern Nuclear Operating Company, Inc.
Electronic Mail Distribution Cynthia A. Sanders
Radioactive Materials Program Manager
R. L. Gladney Environmental Protection Division
Licensing Engineer Georgia Department of Natural Resources
Southern Nuclear Operating Company, Inc. Electronic Mail Distribution
Electronic Mail Distribution
James C. Hardeman
N. J. Stringfellow Environmental Radiation Program Manager
Licensing Manager Environmental Protection Division
Southern Nuclear Operating Company, Inc. Georgia Department of Natural Resources
Electronic Mail Distribution Electronic Mail Distribution
Paula Marino William D. Oldfield
Vice President Principal Licensing Engineer
Engineering Joseph M. Farley Nuclear Plant
Southern Nuclear Operating Company, Inc. Electronic Mail Distribution
Electronic Mail Distribution
(cc w/encl 1 continued next page)
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SNC 5
(cc w/encl 1 continued)
Mr. Mark Culver
Chairman
Houston County Commission
P. O. Box 6406
Dothan, AL 36302
James A. Sommerville
Program Coordination Branch Chief
Environmental Protection Division
Georgia Department of Natural Resources
Electronic Mail Distribution
James L. McNees, CHP
Director
Office of Radiation Control
Alabama Dept. of Public Health
P. O. Box 303017
Montgomery, AL 36130-3017
State Health Officer
Alabama Dept. of Public Health
RSA Tower - Administration
Suite 1552
P.O. Box 30317
Montgomery, AL 36130-3017
L. L. Crumpton
Administrative Assistant, Sr.
Southern Nuclear Operating Company, Inc.
Electronic Mail Distribution
F. Allen Barnes
Director
Environmental Protection Division
Georgia Department of Natural Resources
Electronic Mail Distribution
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SNC 5
Letter to L. Michael Stinson from Richard P. Croteau dated June 8, 2011
SUBJECT: JOSEPH M. FARLEY NUCLEAR PLANT, NRC INSPECTION REPORT
05000348/2011-012 AND 05000364/2011-012 AND PRELIMINARY WHITE
FINDING
Distribution w/encl:
RidsNrrPMFarley Resource
C. Evans, RII
L. Douglas, RII
OE Mail
RIDSNRRDIRS
PUBLIC
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
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U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No.: 50-348, 50-364
Report No.: 05000348/2011-012 AND 05000364/2011-012
Licensee: Southern Nuclear Operating Company, Inc.
Facility: Joseph M. Farley Nuclear Plant, Unit 1
Location: Columbia, AL
Dates: November 10, 2010 - May 24, 2011
Inspectors: W. Rogers, Senior Reactor Analyst (Section 4OA5)
E. Crowe, Senior Resident Inspector (Section 4OA5)
J. Sowa, Resident Inspector (Section 4OA5)
Approved by: Scott M. Shaeffer, Chief
Reactor Projects Branch 2
Division of Reactor Projects
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Enclosure 1
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SUMMARY OF FINDINGS
IR 05000348/2011012. 05000364/2011012; 11/10/2010 - 5/24/2011; Joseph M. Farley Nuclear
Plant; Unit 1; Other Activities.
The report transmits the results of the NRCs preliminary assessment of the 1A RCP handswitch
fire. One self-revealing finding and Apparent Violation with potentially low to moderate safety
significance (White) was identified. The significance of most findings is indicated by their color
(great than Green, or Green, White, Yellow, Red); the significance was determined using
Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP); the cross-
cutting aspect was determined using IMC 0310, Components Within The Cross-Cutting Areas;
and that findings for which the SDP does not apply may be Green or be assigned a severity
level after NRC management review.
Cornerstone: Initiating Events
- TBD. A self-revealing finding and apparent violation of Technical Specification 5.4,
Procedures, was identified for failing to maintain the configuration of the 1A RCP oil lift
pump system in accordance with plant design and drawings. The licensee incorrectly re-
landed electrical wiring following maintenance to the 1A RCP oil lift pump pressure
switch. This issue revealed itself upon the discovery of a flame on the 1A RCP
handswitch in the Unit 1 main control room (MCR).
The licensees failure to maintain the configuration of the 1A RCP oil lift pump system in
accordance with plant design and drawings is a performance deficiency. Work was
completed, by skill of the craft, without inclusion into an amendment to the existing
calibration work order, and resulted in the incoming electrical feeds for the 125 vDC and
130 vAC circuits being cross-connected and causing a fire on the MCR board when the
1A RCP handswitch was taken to start. The finding is more than minor because it was
associated with the Protection Against External Factors attribute of the Initiating Events
cornerstone to limit the likelihood of those events that upset plant stability and challenge
critical safety functions during shutdown as well as power operations. Specifically, a fire
occurred in the MCR for Units 1 and 2 as a result of the mis-wiring causing an electrical
short in the 1A RCP handswitch. This finding was assessed using the Phase 1
screening worksheets of Appendix 4 and Appendix F of MC 0609, and warranted a
review by a regional Senior Risk Analyst because a fire in the MCR had actually
occurred. The regional Senior Risk Analysts determined the significance of this finding
is preliminarily White. The finding does not represent an immediate safety concern
because the wiring has been returned to the original plant design. The finding was
assigned a cross-cutting aspect in the Work Practices component of the Human
Performance area in that personnel did proceed in the face of uncertainty or unexpected
circumstances. H.4(a)
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Enclosure 1
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3
4. OTHER ACTIVITIES
4OA5 Other
Mis-wiring of the 1A RCP oil lift pump pressure switch results in flame on the 1A RCP
handswitch.
a. Inspection Scope
The inspectors conducted an in-office review and significance evaluation of the events
which led to the 1A RCP handswitch fire.
b. Findings
Introduction A self-revealing finding and apparent violation (AV) of TS 5.4, Procedures,
was identified for failing to maintain the configuration of the 1A RCP oil lift pump system
in accordance with plant design and drawings. The licensee incorrectly re-installed
electrical wiring following maintenance to the 1A RCP oil lift pump pressure switch. This
issue revealed itself upon the discovery of a flame on the 1A RCP handswitch in the Unit
1 MCR board.
Description On November 10, 2010, with Unit 1 shutdown for the refueling outage
(RFO), the licensee attempted to start the 1A RCP. The control room operator noticed
the amber light for the switch position miss-match indication illuminate, heard an audible
noise coming from the 1A RCP handswitch and noticed the presence of smoke coming
from the handswitch. The control room operator and control room supervisor
investigated the smoke by removing the light array from the handswitch and opening the
door to the back of the MCR board panel. Each individual noticed a flame of
approximately one inch in height emanating from the handswitch. The fire was
extinguished by personnel blowing out the flame, after multiple attempts. The estimated
fire duration was approximately one minute.
Leading up to this event, the licensee had recently completed calibration of the 1A RCP
oil lift pump pressure switch during the RFO. During the calibration, workers noticed
damage to wiring on the oil lift pump pressure switch. The workers involved in the
calibration replaced the damage conduit in the containment building and later discussed
the replacement of the conduit with their supervisor. Work was completed by skill of the
craft without inclusion into the calibration or other work order. The conduit replacement
resulted in the removal of the pressure switchs electrical wiring from its 125 vDC and
130 vAC circuits. The licensees event review determined that during the re-installation
of the electrical wiring for the oil pressure switch, the incoming electrical feeds for the
125 vDC and 130 vAC circuits were swapped resulting in the AC and DC circuits being
cross-connected creating the path for an electrical short when the associated control
room 1A RCP handswitch was taken to the start position.
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Enclosure 1
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4
The inspectors reviewed licensee work order (WO) 1063205801 which included station
procedure FNP-0-IMP-425.3, Pressure Actuated Switches (Generic). The inspectors
discovered that FNP-0-IMP-425.3, section 7.4, controls the switch replacement and that
step 7.4.3 requires the technician to make note of lead locations on the pressure switch
terminals then disconnect and remove the field leads. The licensee utilizes skill of the
craft to ensure proper landing of electrical leads at the station. The licensees planners
also include a generic data sheet in work orders that lift and land leads to electrical
components. This generic data sheet was not used since it is not formally required, but
serves as an aid to the technician. The inspectors also reviewed statements from
individuals involved in the lifting and landing of the wires. The individuals indicated that
they wiggled wires on one end of the conduit as their means to locate that wire at the
other end of the conduit. The licensee did not amend the original work order or re-plan
the work activity in order to effect repair to the damaged conduit. The licensee entered
this event into its corrective action program (CAP) as CR 201011613.
Analysis The licensees failure to maintain the configuration of the 1A RCP oil lift pump
system in accordance with plant design and drawings is a performance deficiency. Work
was incorrectly completed by skill of the craft without replanning the calibration work
order. Conduct of the work directly resulted in the incoming electrical feeds for the 125
vDC and 130 vAC circuits being cross-connected. The finding is more than minor
because it was associated with the Protection Against External Factors attribute of the
Initiating Events cornerstone to limit the likelihood of those events that upset plant
stability and challenge critical safety functions during shutdown as well as power
operations. An electrical short in the 1A RCP handswitch resulted in a fire occurring in
the MCR for Units 1 and 2. The NRC staff determined the fire to be potentially
challenging (i.e. if not suppressed, the fire could have eventually lead to a MCR
evacuation). The determination that the fire was potentially challenging was based upon
the subjective classification criteria of NUREG-6850, Fire PRA Methodology For Nuclear
Power Plants, Appendix C, Section C.2.3.2, Subjective Classification Criteria.
Specifically, this was considered to be a fire requiring active intervention to prevent
spread. This finding was assessed using the Phase 1 screening worksheets of
Appendix 4 and Appendix F of MC 0609, and warranted a review by a regional Senior
Risk Analyst because a fire in the MCR had actually occurred. The regional Senior Risk
Analysts determined the significance of this finding is preliminarily White. The finding
does not represent an immediate safety concern because the wiring has been returned
to the original plant design. The finding was assigned a cross-cutting aspect in the Work
Practices component of the Human Performance area in that personnel did proceed in
the face of uncertainty or unexpected circumstances. H.4(a)
Enforcement TS 5.4.1 a, states in part that written procedures shall be established,
implemented, and maintained covering the applicable procedures recommended in
Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide
1.33, Appendix A states, in part, that maintenance that can affect the performance of
safety-related equipment should be properly preplanned and performed in accordance
with written procedures, documented instructions, or drawings appropriate to the
circumstances. Contrary to the above, on November 10, 2010, the licensee failed to
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Enclosure 1
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5
properly preplan and perform maintenance that affected safety-related equipment.
Specifically, maintenance and repair activities were performed on the 1A RCP oil lift
pump pressure switch wiring in the Unit 1 containment using skill of the craft techniques
and without an approved amendment to WO 1063205801. During maintenance repair
activities for the 125 vDC and 130 vAC circuits on the 1A RCP oil lift pump pressure
switch, the proper wiring configuration was not maintained or accomplished in
accordance with Drawing D-177249, Elementary Diagram Reactor Coolant Pump
Bearing Lift Oil Pumps, Version 2.0. During subsequent activities to return Unit 1 to
power operation on November 10, 2010, licensed operators attempted to start the 1A
RCP. As a result of the mis-wiring, when the 1A RCP control handswitch was taken to
the start position, flame and smoke emanated from the handswitch, from the top and
under the MCR board, thereby presenting a challenge to safety-related equipment
inside and adjacent to the MCR board. The licensee has returned the wiring to its
original plant design and the licensee has entered this issue into their corrective action
program as CR 2010116613. URI 05000348/2010005-03, opened in NRC Inspection
Report Number 05000348/2010005 and 0500364/2010005 is closed. Pending final
significance determination, this finding is identified as AV 05000348,364/2011012-01,
Flame Detected on the 1A RCP Handswitch.
4OA6 Meetings, Including Exit
On June 8, 2011, the NRC presented the inspection results to Mr. T. Youngblood who
acknowledged the findings.
ATTACHMENT: SUPPLEMENTAL INFORMATION
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Enclosure 1
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SUPPLEMENTAL INFORMATION
LIST OF REPORT ITEMS
Opened
05000348, 364/2011012-01 AV Flame Detected on the 1A RCP Handswitch
(Section 4OA5)
Closed
05000348/2010005-03 URI Flame Detected on the 1A RCP Handswitch
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Attachment