IR 05000348/2012005
| ML13031A490 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 01/31/2013 |
| From: | Frank Ehrhardt NRC/RGN-II/DRP/RPB2 |
| To: | Lynch T Southern Nuclear Operating Co |
| References | |
| IR-12-005 | |
| Download: ML13031A490 (32) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ary 31, 2013
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000348/2012005 AND 05000364/2012005
Dear Mr. Lynch:
On December 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Joseph M. Farley Nuclear Plant, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on January 7, 2013, with you and members of your staff.
The inspectors examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
No NRC-identified or self-revealing findings were identified during this inspection. However, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest this non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Joseph M.
Farley Nuclear Plant. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response, if any, will be available electronically for public inspection in the NRC public document room or from the publicly available records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the public electronic reading room).
Sincerely,
/RA/
Frank Ehrhardt, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos.: 50-348, 50-364 License No.: NPF-2, NPF-8
Enclosure:
Inspection Report 05000348/2012005 and 05000364/2012005 w/Attachment: Supplemental Information
REGION II==
Docket Nos.: 05000348, 05000364 License Nos.: NPF-2, NPF-8 Report No.: 05000348/2012005 and 05000364/2012005 Licensee: Southern Nuclear Operating Company, Inc.
Facility: Joseph M. Farley Nuclear Plant, Units 1 and 2 Location: Columbia, AL Dates: September 1, 2012 through December 31, 2012 Inspectors: E. Crowe, Senior Resident Inspector J. Sowa, Resident Inspector M. Coursey, Reactor Inspector (4OA5.6)
B. Caballero, Senior Operations Engineer (1R11.3)
J. Laughlin, Emergency Preparedness Inspector (1EP4)
M. Riley, Reactor Inspector (4OA5.5)
Approved by: Frank Ehrhardt, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000348/2012005 and 05000364/2012005; 9/01/12, - 12/31/12; Joseph M. Farley Nuclear
Plant; Integrated Report.
The report covered a three-month period of inspection by resident and regional inspectors. No findings were identified during this inspection period. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December, 2006.
NRC- Identified and Self Revealing Findings
No findings were identified.
Violations of very low safety significance or severity level IV that were identified by the licensee have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and corrective actions are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Unit 1 started the report period at 100 percent rated thermal power (RTP). On October 25 the licensee performed an unplanned downpower to 30 percent RTP due to issues associated with the digital electrohydraulic control inverter. The licensee swapped the inverter to its alternate power source and returned the unit to 100 percent RTP on October 26. The unit remained at 100 percent RTP for the remainder of the inspection period.
Unit 2 started the report period at 100 percent RTP. On November 23 the licensee performed a planned downpower to 18 percent RTP to facilitate oil addition to the lower oil reservoir of the 2A reactor coolant pump. The unit returned to 100 percent RTP on November 24 and remained at or near 100 percent RTP for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R04 Equipment Alignment
.1 Partial Walk-Down
a. Inspection Scope
The inspectors verified that critical portions of selected risk-significant systems were correctly aligned. The inspectors selected systems for assessment because they were a redundant or backup system/train, were important for mitigating risk for the current plant conditions, had been recently realigned, or were a single-train system. The inspectors determined the correct system lineup by reviewing plant procedures and drawings. The inspectors verified that critical portions of the selected systems were correctly aligned by performing partial walkdowns. Documents reviewed are listed in the Attachment. The inspectors selected the following system/trains to inspect:
- Unit 2, 1-2A and 1C emergency diesel generators (EDG) and safety-related electrical distribution system during inoperable 2B EDG
b. Findings
No findings were identified.
.2 Complete Walk-Down
a. Inspection Scope
The inspectors verified the alignment of the Unit 1 emergency diesel generator system.
The inspectors selected this system for assessment because it is a risk-significant mitigating system. The inspectors determined the correct system lineup by reviewing plant procedures, drawings, the updated final safety analysis report, and other documents. In order to identify any deficiencies that could affect the ability of the system to perform its function(s), the inspectors reviewed records related to outstanding design issues and maintenance work requests. The inspectors verified that the selected system was correctly aligned by performing a complete walk down of accessible components.
To verify the licensee was identifying and resolving equipment alignment discrepancies, the inspectors reviewed corrective action documents, including condition reports and outstanding work orders, and periodic reports containing information on the status of risk-significant systems, including maintenance rule reports and system health reports.
Documents reviewed are listed in the Attachment.
1R05 Fire Protection
a. Inspection Scope
Quarterly Inspection The inspectors evaluated the adequacy of selected fire plans by comparing the fire plans to the defined hazards and defense-in-depth features specified in the fire protection program. In evaluating the fire plans, the inspectors assessed the following items:
- (1) control of transient combustibles and ignition sources,
- (2) fire detection systems, (3)water-based fire suppression systems,
- (4) gaseous fire suppression systems,
- (5) manual firefighting equipment and capability,
- (6) passive fire protection features, (7)compensatory measures and fire watches, and
- (8) issues related to fire protection contained in the licensees corrective action program (CAP). The inspectors toured the following fire areas to assess material condition and operational status of fire protection equipment. Documents reviewed are listed in the Attachment.
- Unit 1, 1A residual heat removal (RHR) pump room, fire zone 1
- Unit 1, 1B RHR pump room, fire zone 1
- Unit 1, RHR heat exchanger room, fire zone 1
- Unit 2, 2A RHR pump room, fire zone 1
- Unit 2, 2B RHR pump room, fire zone 1
- Unit 2, RHR heat exchanger room, fire zone 1
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification
a. Inspection Scope
The inspectors observed a simulator scenario conducted for training of an operating crew for continuing training. The inspectors assessed licensed operator performance, the ability of the licensee to administer the scenario, the quality of any post-scenario critique, any follow-up actions taken by the facility licensee, and the performance of the simulator. Documents reviewed are listed in the Attachment.
The inspectors assessed licensed operator performance, the ability of the licensee to administer the, the quality of any post-scenario critique, any follow-up actions taken by the facility licensee, and the performance of the simulator. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
.2 Resident Inspector Quarterly Review (Licensed Operator Performance):
a. Inspection Scope
The inspectors observed licensed operator performance in the main control room during a Unit 2 yellow risk condition on October 22, 2012. Inspectors observed licensed operator performance to assess the following:
- Use of plant procedures
- Control board manipulations
- Communications between crew members
- Use and interpretation of instruments, indications, and alarms
- Use of human error prevention techniques
- Documentation of activities
- Management and supervision Document reviewed are listed in the Attachment.
b. Findings
No findings were identified.
.3 Annual Review of Licensee Requalification Examination Results
a. Inspection Scope
On November 30, 2012, the licensee completed administration of the annual requalification operating tests and biennial written exam required for all licensed operators in accordance with 10 CFR 55.59(a)(2). The inspectors performed an in-office review of the overall pass/fail results of the individual operating tests and the crew simulator operating tests. These results were compared to the thresholds established in Manual Chapter 609 Appendix I, Operator Requalification Human Performance Significance Determination Process.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors assessed the licensees treatment of the issues listed below in order to verify the licensee appropriately addressed equipment problems within the scope of the Maintenance Rule (10 CFR 50.65). The inspectors reviewed procedures and records in order to evaluate the licensees identification, assessment, and characterization of the problems as well as their corrective actions for returning the equipment to a satisfactory condition. Documents reviewed are listed in the Attachment.
- CR 482963, emergency air to 1B atmospheric relief solenoid has no manual override
- CR 526515, 1B rod control motor generator set output breaker tripped
b. Findings
One licensee-identified violation was identified and documented in section 4OA7 of this report.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the maintenance activities listed below to verity the licensee assessed and managed plant risk as required by 10 CFR 50.65(a)(4) and licensee procedures. The inspectors assessed the adequacy of the licensees risk assessments and implementation of risk management actions. The inspectors also verified that the licensee was identifying and resolving problems with assessing and managing maintenance-related risk using the corrective action program. Additionally, for maintenance resulting from unforeseen situations, the inspectors assessed the effectiveness of the licensees planning and control of emergent work activities.
Documents reviewed are listed in the Attachment.
- Unit 2, October 22, 2012, YELLOW risk condition associated with planned maintenance on 2B spent fuel pool pump
- Unit 2, November 7, 2012, elevated GREEN risk condition associated with planned maintenance on 2B EDG and B train RHR
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed the operability evaluations listed below in order to verify the requirements of licensee procedures NMP-OS-007, Conduct of Operations and NMP-AD-012, Operability Determinations and Functionality Assessments were met. The inspectors also assessed the technical basis of the evaluations, compensatory measures, and the impact on continued plant operation. Documents reviewed are listed in the Attachment.
- CR 535504, Unit 2, 2B EDG jacket water expansion tank overflowing
- CR 482963, Unit 1, emergency air to 1B atmospheric relief valve (ARV) solenoid has no manual override actuator
- CR 536202, Unit 1, wrong version of under voltage driver and safe guard driver cards installed in solid state protection system (SSPS)
b. Findings
No findings were identified.
1R18 Plant Modifications
a. Inspection Scope
The inspectors reviewed the following plant modification to ensure the safety functions of important safety systems were unaffected. The inspectors also verified the design bases, licensing bases, and performance capability of risk-significant structure, systems, and components (SSCs) had not been degraded through modifications. The inspectors verified any modification performed during a risk-significant configuration did not place the plant in an unsafe condition. Additionally, the inspectors evaluated system operability, availability, configuration control, post-installation test activities, documentation updates, and operator awareness of the modification. Documents reviewed are listed in the Attachment.
Temporary Plant Modifications
- SNC 69135, installation of collar addition to the stem of Q1P17MOV3185B in accordance with the instructions in TM 1111215202
- SNC 87546, installation of collar addition to the stem of Q2P17MOV3185B in accordance with the instructions in TM 2111215801
b. Findings
No findings were identified.
1R19 Post Maintenance Testing
a. Inspection Scope
The inspectors reviewed the criteria contained in licensee procedures FNP-0-PMT-0.0, Post-Maintenance Test Program, to verify post-maintenance test procedures and test activities for the following systems/components were adequate to verify system operability and functional capability. The inspectors also witnessed the test or reviewed the test data to verify test results adequately demonstrated restoration of the affected safety functions. Documents reviewed are listed in the Attachment.
- FNP-1-STP-80.1, Diesel Generator 1 2A Operability Test, following 24 month planned maintenance on 1-2A EDG
- FNP-1-SOP-41.0, Control Rod Drive and Position Indication System, following maintenance on 1A Control Rod Drive Mechanism (CRDM) Motor Generator (MG)set 1A
- FNP-2-STP-16.2, 2B Containment Spray Pump Quarterly Inservice Test, following planned maintenance on 2B containment spray pump
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the following surveillance tests and either observed the test or reviewed test results to verify testing adequately demonstrated equipment operability and met Technical Specification requirements. The inspectors reviewed the activities to assess for preconditioning of equipment, procedure adherence, and correct restoration of system configuration following completion of the surveillance. The inspectors reviewed licensee procedures and attended selected briefings to determine if procedure requirements were met. Documents reviewed are listed in the Attachment.
Surveillance Tests
- FNP-2-STP- 16.12A, 2A Containment Spray Pump Automatic Starting Circuitry Test In-Service Test (IST)
- FNP-2-STP-16.1, 2A Containment Spray Pump Quarterly Inservice Test
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness (EP)
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
The office of Nuclear Security and Incident Response staff performed an in-office review of the latest revisions of various Emergency Plan Implementing Procedures (EPIPs) and the Emergency Plan located under ADAMS accession numbers ML12061A039, ML12081A211, ML12093A204, and ML12188A352, as listed in the Attachment.
The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the Emergency Plan, and that the revised Emergency Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, these revisions are subject to future inspection. Documents reviewed are listed in the Attachment. This inspection activity satisfied one inspection sample for the emergency action level and emergency plan changes on an annual basis.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
a. Inspection Scope
The inspectors sampled licensee data for the performance indicators (PIs) listed below to verify the accuracy of the PI data reported on the NRC public website. The inspectors used Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Indicator Guideline, Rev. 6, to verify the basis for reporting for each data element. Documents reviewed are listed in the Attachment.
Cornerstone: Initiating Events
- Unplanned Scrams with Complications
Cornerstone: Mitigating Systems
- Cooling Water System
- High Pressure Injection System
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Daily Condition Report Reviews
As required by IP 71152, Identification and Resolution of Problems, and in order identify repetitive equipment failures or human performance issues for follow-up, the NRC performed a daily screening of items entered into the licensees CAP. This review was accomplished by reviewing copies of Condition Reports (CRs), attending daily screening meetings and accessing the licensees computerized database.
.2 Selected Issue Follow-up Inspection
a. Inspection Scope
The inspectors selected the issues listed below for more in-depth reviews. The inspectors considered the following during the review of the licensees actions:
- (1) complete, accurate, and timely identification of the problem,
- (2) evaluation and disposition of operability/reportability,
- (3) extent of condition, generic implications, common cause, and previous occurrences,
- (4) classification and prioritization of the problem resolution,
- (5) identification of root and contributing causes of the problem,
- (6) identification of CRs, and
- (7) timely completion of corrective actions.
- CR 476489, control room seismic computer inoperable
- CR 482558, loss of plant security system
b. Observations and Findings
CR 476489: The control room seismic computer printer failed on May 4, 2012 making the control room seismic computer inoperable. Control room operators use printouts generated by this seismic monitoring equipment to determine if the Operating Basis Earthquake (OBE) criteria was exceeded. The control room seismic computer was, therefore, incapable of providing meaningful input to the emergency action level (EAL)classification process. As a result, a seismic event declaration based on EAL HA1.1 could not be made.
The licensee completed a 10 CFR 50.54q screening/evaluation document which stated that seismic history data obtained from the EDG seismic instrument could be used to classify an Alert emergency action level based on EAL HA1.1 in a timely manner. The evaluation also detailed compensatory measures for plant personnel to implement while the seismic computer was inoperable. Compensatory measures included directing technicians to collect data from the integral digital solid state recorder for the EDG building seismic instrument per procedure FNP-0-STP-254.2, and to evaluate the data against OBE criteria found in Table 1 of annunciator response procedure FNP-1-ARP-1.12. The inspectors interviewed station personnel and discovered the data obtained from the EDG seismic monitor could be interpreted by an off-site vendor, Kinemetrics, in order to determine if the OBE criteria had been exceeded. Since the licensee could not interpret the information they would need to send the data offsite for vendor interpretation.
Additionally, the licensee indicated that an Alert condition based on EAL HA1.1 could be declared based on procedural steps of annunciator response procedure FNP-1-ARP-1.12 for the MK5 Seismic Panel Alarm. Specifically, the procedure directs the licensee to perform operator walkdowns of vital component areas of the plant. If significant damage is found during walkdowns, then the procedure indicates OBE criteria has been exceeded and the licensee would subsequently declare an Alert condition.
The licensee could not repair the system because of its obsolescence. The licensee has identified suitable replacement parts and the seismic monitor computer is scheduled to return to service in early 2013.
After reviewing the licensees compensatory actions for an out of service seismic monitor computer and the plan to replace the system with new, modernized equipment due to obsolescence, the inspectors did not identify a performance deficiency.
CR 482558: On July 10, 2012, personnel attempting to remove a scaffold tree from behind a permanent plant ladder in the security diesel building caused a loss of plant security equipment. Personnel accomplished the removal of the scaffold tree under housekeeping activities and without the aid of a planned work order. The scaffold tree came into contact and cut through the insulation of the 480V electrical feed cable to the security interface systems. This contact caused an electrical short to ground, causing the supply breaker to trip open; which, in turn, caused a loss of security interface systems. The licensee implemented the appropriate compensatory measures.
The licensee installed the scaffold to support installation of a cable raceway and electrical cables by contract personnel wiring the security diesel building. During this work activity, the licensee also installed a permanent ladder which inhibited the complete removal of the installed scaffold and resulted in a single scaffold tree not being removed during the scaffold disassembly. The licensee discovered the presence of this single scaffold tree during a routine plant housekeeping inspection. The scaffolding tree could not be extricated without removing a permanently installed ladder or cutting the scaffolding tree and a condition report should have been initiated as required by station procedure FNP-0-ACP-35.1, Plant Housekeeping Inspection Guidance. Step 4.2 of FNP-0-ACP-35.1 states, Each housekeeping item identified that cannot be resolved by the group performing the inspection should be addressed using the condition reporting system for resolution. Licensee personnel captured this item in a housekeeping database outside the corrective action process. This prevented the preparation of a minor work order which would have been reviewed by appropriate station personnel.
This oversight resulted in the failure to identify the potential electrical hazard and risk to security equipment. NMP-GM-006-GL01, Work Planning, Packaging, and Closure require the evaluation of risk during the generation of work order including minor work orders.
Workers involved in this work activity conducted a pre-job brief prior to the start of work.
The brief included the need to remove the tree intact if possible and included a backup plan to cut the tree in half if it could not be removed in one piece. The workers evaluated the area for bump-sensitive equipment but did not identify the full risk involved with this activity and did not establish adequate barriers to prevent contact with the electrical cable in the cable raceway. The workers attempted to remove the scaffold tree intact by lifting the tree up and out from behind the ladder. The scaffold tree inadvertently made contact with and cut through the insulation jacket of the 480V feeder cable, and a short circuit resulted in the loss of power to the security interface systems.
The inspectors determined that the licensees failure to generate a condition report as required by FNP-0-ACP-35.1, Step 4.2 was a performance deficiency. The performance deficiency was considered minor because the physical security cornerstone objective to ensure the availability, reliability, and capability of security systems was not adversely affected. Specifically, the licensee implemented compensatory measures which ensured the cornerstone objective was maintained.
.3 Semi-Annual Trend Review
a. Inspection Scope
As required by IP 71152, Identification and Resolution of Problems, the inspectors performed a review of the licensees CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors reviewed repetitive equipment and corrective maintenance issues, and also considered the results of daily inspector CAP item-screening discussed above. The inspectors also reviewed issues documented outside the normal CAP process, corrective maintenance WOs, component status reports, and maintenance rule assessments. The inspectors review nominally considered the six month period of June 1, 2012 through December 31, 2012, although some examples expanded beyond those dates when the scope of the trend warranted. Corrective actions associated with a sample of the issues identified in the licensees trend report were reviewed for adequacy. Documents reviewed are listed in the Attachment.
b. Assessment The inspectors evaluated the following six condition reports that document human performance events. Except as noted, each of these events involved minor procedural violations where station personnel failed to correctly implement station procedures. The inspectors discussed these events with licensee management to gain insight as to the cause of the events. The inspectors learned the licensee performed a causal analysis and Human Performance Review Board for each individual event. The Maintenance Department identified the need to address performance gaps in Ineffective Leadership and Human Performance. The department is utilizing their performance improvement integrated matrix to formulate and complete corrective actions. Significant actions included conducting oral boards for all supervisors. Managers performed both paired and parallel observations of each supervisor to verify adequate understanding and enforcement of company standards. An Out of the Box Evaluation process has been implemented to evaluate and assess each journeymans understanding and use of human performance tools as well as evaluate compliance with department standards and expectations. Unsatisfactory performance during these evaluations results in remediation of the individuals. The observation program requires supervisors to provide daily feedback to their work groups to improve the effectiveness of the observation program. These observations are documented in each individuals performance notes.
The inspectors continue to monitor the effectiveness of the above corrective actions.
- CR 434764, inadvertent de-energization of 1F 4160V bus during performance of FNP-1-STP-40.0 (dispositioned as a Green NCV in Integrated Inspection Report 2012004)
- CR 466775, Unit 1 train A SSPS temporary modification to install a jumper around a portion of the input error inhibit ground circuit had a step omitted
- CR 477134, Unit 2 loss of main control board troubleshooting pulled unintended annunicator cards
- CR 485253, incorrect installation of jumpers caused unplanned actuation of steam generator blowdown outlet isolation valves
- CR 501379, incorrect comparator test switch was operated during loop calibration of pressurizer level transmitter LT460
- CR 467468, one of the K1 auxiliary relays was discovered to be improperly mounted on the side of the relay for the generator field circuit of the 1C emergency diesel generator (dispositioned as a Green NCV in Integrated Inspection Report 2012004)
4OA3 Follow-up of Events and Notices of Enforcement Discretion
.1 (Closed) LER 05000348/2012-005-00 Unit Shutdown Required by Technical
Specification 3.8.1 and URI 05000348/2012004-03 LER 05000348/2012-005-00 Unit Shutdown Required by Technical Specification 3.8.1
a. Inspection Scope
The inspectors reviewed this Licensee Event Report (LER) and Unresolved Item (URI)for potential performance deficiencies and/or violations of regulatory requirements.
Additionally, discussions were held with operations, engineering, and licensing staff members to understand the details surrounding this issue. This condition was documented in the licensees CAP as Condition Report (CR) 487817. LER 05000348/2012-005 and URI 05000348/2012004-03 are closed.
b. Assessment Inspectors reviewed CR 487817, CAP 195378 and other documents associated with this event. The inspectors performed a search of the licensees CAP for other associated events. From the above review, the inspectors determined the cause of the event was a random failure of 1B EDG thermostatic control valve. The inspectors discovered from the licensees cause determination that OE34938 was sent to the industry for stations with similar temperature control valves. OE34938 recommended evaluation of the preventative maintenance frequency for the need to lower the frequency to 3 years instead of the 10 years provided by the Fairbank Morse Owners Group. The licensee had lowered their preventive maintenance frequency to 6 years previously and the valve which failed was scheduled for maintenance at the end of 2012. The inspectors reviewed station logs and observed licensee activities during the implementation of the unit shutdown. The licensee performed the unit shutdown in accordance with station procedures and in a timely manner coincident with required allowed times specified within technical specification 3.8.1. The inspectors monitored the licensees repairs and post maintenance testing. No findings or violations of NRC requirements were identified.
4OA5 Other Activities
.1 Resident Inspection Observations of Independent Spent Fuel Storage Installation
a. Inspection Scope
The licensee performed a dry fuel cask loading campaign during this inspection period.
The inspectors monitored work activities associated with the campaign to ensure cask loading was accomplished per station procedures. The inspectors walked down the cooling systems related to loading and drying activities of the Multi-Purpose Canister (MPC). The inspectors also reviewed licensees compensatory measures for alternate cooling and the maintenance of water level in the MPC during fuel loading. The inspectors reviewed changes made to licensee procedures since the last dry fuel cask loading campaign in 2010 to verify the changes were consistent with the license and Certificate of Compliance, and did not reduce the program effectiveness.
b. Findings
No findings were identified.
.2 (Closed) URI 05000348/364/2011008-001: Evaluation of Potential Tornado Missile
Density to Bound TORMIS Evaluation
a. Inspection Scope
During the Farley 2011 Problem Identification and Resolution inspection an issue regarding the diesel generator fuel oil storage tank TORMIS evaluation was identified.
The NRC questioned whether the potential effects of ongoing construction at Farley in 2011 were evaluated and bounded by the existing TORMIS analysis and 2001 Safety Evaluation Report (SER). The TORMIS model and its use are described in RIS 2008-14 and associated documents referenced therein. One of the five points discussed in the RIS is that missile density and missile proximity to safety-related and risk-significant SSCs are important factors in the use of TORMIS, especially as conditions may change at the site due to specific work activities. During 2011, the licensee conducted extensive construction work which included staging and relocation of required equipment and material. The licensee was asked for an assessment of the change in the number of potential tornado missiles created by the ongoing construction projects which is a required component of the application of the TORMIS model for identifying if additional protection is required for safety-related SSCs.
The licensee entered the issue into the corrective action process and completed a TORMIS evaluation in July of 2012. The inspectors reviewed the licensees 2012 TORMIS Calculation. The inspectors review included evaluation of any additional targets added to the evaluation and the potential risk represented by these potential missiles. This calculation contained a comparison of results of the 1999 TORMIS Calculation with the 2012 TORMIS Calculation. The inspectors determined that no significant difference existed between the two calculations and only a slight increase in risk was identified by the 2012 TORMIS Calculation. The inspectors interviewed station personnel regarding the slight increased risk that resulted from different calculation methodologies. The inspectors discovered the licensee is planning modifications to the plant to address this slight increase in risk. The inspectors also discussed the use the licensees process of evaluating changes in tornado missile density for ongoing site activities. Additionally the inspectors reviewed the results of the 2012 TORMIS calculation with regard to construction projects that were in progress at the time the URI was open. The URI is closed.
b. Findings
No findings were identified.
.3 (Discussed) NRC Temporary Instruction (TI) 2515/187, Inspection of Near-Term Task
Force Recommendation 2.3 Flooding Walkdowns
a. Inspection Scope
Inspectors conducted independent walkdowns to verify that the licensee completed the actions associated with the flood protection feature specified in paragraph 03.02.a.2 of this TI. Inspectors are performing walkdowns at all sites in response to a letter from the NRC to licensees, entitled Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident, dated March 12, 2012 (ADAMS Accession No. ML12053A340).
4 of the letter requested licensees to perform external flooding walkdowns using an NRC-endorsed walkdown methodology (ADAMS Accession No.
ML12056A050). Nuclear Energy Industry (NEI) document 12-07 titled, Guidelines for Performing Verification Walkdowns of Plant Protection Features, (ADAMS Accession No. ML12173A215) provided the NRC-endorsed methodology for assessing external flood protection and mitigation capabilities to verify that plant features, credited in the CLB for protection and mitigation from external flood events, and are available, functional, and properly maintained.
b. Findings and Observations
Findings or violations associated with the flooding, if any, will be documented in the 1st quarter integrated inspection report of 2013.
.4 (Closed) NRC Temporary Instruction (TI) 2515/188, Inspection of Near-Term Task
Force Recommendation 2.3 Seismic Walkdowns
a. Inspection Scope
The inspectors accompanied the licensee on their seismic walkdowns of the Unit 1 B train emergency DC battery room, and Unit 1 and Unit 2 main control rooms to verify that the licensee confirmed that the following seismic features associated with these areas were free of the following potential adverse seismic conditions:
- Anchorage was free of bent, broken, missing or loose hardware
- Anchorage was free of corrosion that is more than mild surface oxidation
- Anchorage was free of visible cracks in the concrete near the anchors
- Anchorage configuration was consistent with plant documentation.
- SSCs will not be damaged from impact by nearby equipment or structures.
- Overhead equipment, distribution systems, ceiling tiles and lighting, and masonry block walls are secure and not likely to collapse onto the equipment.
- Attached lines have adequate flexibility to avoid damage.
- The area appears to be free of potentially adverse seismic interactions that could cause flooding or spray in the area.
- The area appears to be free of potentially adverse seismic interactions that could cause a fire in the area.
- The area appears to be free of potentially adverse seismic interactions associated with housekeeping practices, storage of portable equipment, and temporary installations (e.g., scaffolding, lead shielding).
The inspectors independently performed a walkdown to verify that the following structure also met the above bulleted criteria:
- Unit 2 Refueling Water Storage Tank (RWST), September 12, 2012 Observations made during the walkdown that could not be determined to be acceptable were entered into the licensees CAP for evaluation.
Additionally, the inspectors verified that items that could allow the spent fuel pool to drain down rapidly were added to the Seismic Walkdown Equipment List (SWEL) and these items were walked down by the licensee.
b. Findings and Observations
No findings were identified.
.5 (Closed) URI 05000348, 364/2011010-10: Administrative Controls in lieu of Automatic
Actions for Degraded Voltage Protection (ML113530575)
a. Inspection Scope
During the 2011 component design bases inspection, an unresolved item was identified regarding the licensees use of administrative controls in lieu of automatic degraded voltage protection to assure adequate voltage to safety-related equipment during design basis events for meeting 10 CFR 50.55a(h)(2) and 10 CFR 50, Appendix A, Criterion 17, Electric Power Systems (GDC 17). Farleys current system configuration, which relies on administrative actions, was recognized as a deviation from the guidance on degraded voltage protection provided in a NRC letter (dated June 2, 1977), but was accepted by the NRC in a safety evaluation report (dated November 21, 1995).
This same issue was identified at the Edwin I. Hatch Plant, another Southern Nuclear Company facility. The NRC issued a compliance backfit letter (ML111450793) in which the staff concluded that in the 1995 safety evaluation report, the NRC erred in accepting the use of administrative controls for meeting 10 CFR 50.55a(h)(2) and GDC 17.
Southern Nuclear Company appealed this compliance backfit. Due to the similarities with the Hatch backfit, this issue at Farley was considered an unresolved item pending completion of the backfit appeal process. On June 19, 2012, the NRC completed its review of the appeal and issued a letter to Southern Nuclear Company (ML12130A135)upholding the backfit.
On September 28, 2012, Southern Nuclear Company issued a letter to the NRC (ML12276A109) stating that by December 31, 2012, they will submit a license amendment request to update Farley Nuclear Plants current operating license with proposed completion dates for modifications which will eliminate the use of administrative controls in lieu of automatic degraded voltage protection to assure adequate voltage to safety-related equipment during design basis events. The inspectors reviewed the letter and agreed that the licensees proposed actions were adequate to address the issue. Because the use of administrative controls to assure adequate voltage to safety-related equipment during design basis events was accepted by the NRC in a safety evaluation report, the inspectors concluded that no performance deficiency existed. This unresolved item is closed.
b. Findings and Observations
No findings were identified.
.6 (Discussed) NRC Temporary Instruction (TI) 2515/182, Review of the Industry Initiative
to Control Degradation of Underground Piping and Tanks (Phase 1)
a. Inspection Scope
Leakage from buried and underground pipes has resulted in ground water contamination incidents with associated heightened NRC and public interest. The industry issued a guidance document, Nuclear Energy Institute (NEI) 09-14, Guideline for the Management of Buried Piping Integrity (ADAMS Accession No. ML1030901420) to describe the goals and required actions (commitments made by the licensee) resulting from this underground piping and tank initiative. On December 31, 2010, NEI issued Revision 1 to NEI 09-14, Guidance for the Management of Underground Piping and Tank Integrity, (ADAMS Accession No. ML110700122), with an expanded scope of components which included underground piping that was not in direct contact with the soil and underground tanks. On November 17, 2011, the NRC issued TI-2515/182 Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks to gather information related to the industrys implementation of this initiative.
The inspectors reviewed the licensees programs for buried pipe, underground piping and tanks in accordance with TI-2515/182 to determine if the program attributes and completion dates identified in Sections 3.3 A and 3.3 B of NEI 09-14 Revision 1 were contained in the licensees program and implementing procedures. For the buried pipe and underground piping program attributes with completion dates that had passed, the inspectors reviewed records to determine if the attribute was in fact complete and to determine if the attribute was accomplished in a manner which reflected good or poor practices in program management.
b. Observations The licensees buried piping and underground piping and tanks program was inspected in accordance with paragraphs 03.01.a through 03.01.c of TI-2515/182 and was found to meet all applicable aspects of NEI 09-14 Revision 1, as set forth in Table 1 of the TI.
Based upon the scope of the review described above, Phase 1 of TI-2515/182 was completed.
c. Findings
No findings were identified.
.7 Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope
The inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours.
These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status review and inspection activities.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
The NRC presented the inspection results to Mr. Tom Lynch, Site Vice President, and members of the licensee staff on January 7, 2013. The staff acknowledged the results.
The NRC confirmed proprietary information was not provided or examined during the inspection.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance (Green) was identified by the licensee, and is a violation of NRC requirements which meets the criteria of Section 2.3.2 of the NRC Enforcement Policy for being dispositioned as a Non-Cited Violation.
- 10 CFR 50, Appendix B, Criterion III states in part that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled. Contrary to the above, on June 15, 2012, licensee staff installed an incorrect part into the control air circuit of the 1B atmospheric dump valve which resulted in an unapproved design change to the plant. Specifically, the solenoid valve which controls air to the 1B atmospheric dump valve in local operation was replaced with a solenoid valve without a manual operator. The design deficiency was discovered during a training evolution by trainees attempting to implement the steps of an emergency operating procedure. The licensee entered this condition into their CAP as CR 482963. This finding was assessed using IMC 06 and Appendix A screening worksheets and was determined to be of very low safety significance (Green), because the finding is a deficiency affecting the design or qualification of a mitigating system SSC.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- M. Ajluni, Nuclear Licensing Director
- M. Byrd, Design Engineering Supervisor
- T. Campbell, Nuclear Oversight
- D. Christianson, Training Manager
- M. Galle, Simulator Coordinator
- C. Gayheart, Plant Manager
- R. Gayheart, Fleet Training Manager
- D. Hall, Operations Training Supervisor
- D. Hobson, Operations Support
- L. Hogg, Nuclear Technical Specialist
- J. Horn, Site Support Manager
- F. Hundley, Fleet Oversight Supervisor
- P. Ivey, Regulatory Affairs Vice President
- T. Lynch, Site Vice President
- R. Martin, Engineering Programs Manager
- S. McGavin, Security Manager
- D. McKinney, Regulatory Response Manager
- R. Odom, Operations Lead Instructor
- M. Peel, Medical Services Coordinator
- L. Riley, Performance Improvement
- C. Salter, Nuclear Duty Officer
- L. Smith, Maintenance Manager
- B. Taylor, Performance Improvement Supervisor
- C. Thornell, Operations Director
- S. Varnum, CHM Manager
- W. Vierkandt, Radiation Protection Manager
- C. Westberry, Engineering Systems Manager
NRC personnel
Frank Ehrhardt, Chief, Branch 2, Division of Reactor Projects
LIST OF REPORT ITEMS
Opened
None
Opened and Closed
None
Closed
- 05000348/2012005-00 LER Unit Shutdown Required by Technical Specification 3.8.1 (Section 4OA3)
- 05000348/364/2011008-001 URI Evaluation of Potential Tornado Missile Density to Bound TORMIS Evaluation (Section 4OA5.2)
- 05000348/364/2011010-10 URI Administrative Controls in lieu of Automatic Actions for Degraded Voltage Protection (Section 4OA5.5)
- 05000348/2012-0015-00 Unit Shutdown Required by Technical Specification 3.8.1 (4OA3.1).
- 05000348/364/2515/188 TI Inspection of Near-Term Task Force Recommendation 2.3 Seismic Walkdowns (Section 4OA5.4)
Discussed
- 05000348/364/2515/182 TI Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks Phase 1 (Section 4OA5.6)
- 05000348/364/2515/187 TI Inspection of Near-Term Task Force Recommendation 2.3 Flooding Walkdowns (Section 4OA5.3)