IR 05000348/2018012

Nuclear Regulatory Commission Team Inspection Report 05000348/2018012 and 05000364/2018012

ML18218A291
Person / Time
Site:	Farley
Issue date:	08/06/2018
From:	Shane Sandal Reactor Projects Region 2 Branch 6
To:	Madison D Southern Nuclear Operating Co
References
IR 2018012
Download: ML18218A291 (13)

Text

August 6, 2018

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT - NUCLEAR REGULATORY COMMISSION TEAM INSPECTION REPORT 05000348/2018012 AND 05000364/2018012

Dear Mr. Madison:

On June 28, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Joseph M. Farley Nuclear Plant, Units 1 and 2. The NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

The inspection examined activities conducted under your license as they relate to the implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, your compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel.

The NRC inspectors did not identify any finding or violation of more than minor significance.

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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding. If you have any questions, please contact me at 404-997-4513.

Sincerely,

/RA/

Shane Sandal, Chief Reactor Projects Branch 6 Division of Reactor Projects

Docket Nos. 50-348, 50-364 License Nos. NPF-2, NPF-8

Enclosure:

IR 05000348/2018012, 05000364/2018012

Inspection Report

Docket Numbers:

50-348, 364

License Numbers:

NPF-2, NPF-8

Report Numbers:

05000348/2018012; and 05000364/2018012

Licensee:

Southern Nuclear Operating Company, Inc.

Facility:

Joseph M. Farley Nuclear Plant

Location:

Columbia, Alabama

Inspection Dates:

June 25 - 28, 2018

Inspectors:

G. MacDonald, Senior Reactor Analyst (Team Leader)

B. Bishop, Project Engineer

K. Miller, Resident Inspector

K. Roche, Project Manager (NRR/BDBEB)

Approved By:

S. Sandal, Chief

Reactor Projects Branch 6

Division of Reactor Projects

SUMMARY

The NRC continued monitoring licensees performance by conducting a Temporary Instruction (TI) 2515/191, Implementation of Mitigation Strategies and Spent Fuel Pool (SFP)

Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, inspection (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18191B074) at Joseph M. Farley Nuclear Plant, Units 1 and 2, 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

No findings or violations of more than minor significance were identified.

Additional Tracking Items

Type Issue number Title Report Section Status TI TI 2515/191 Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans Other Activities Closed

TABLE OF CONTENTS

INSPECTION SCOPE

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

INSPECTION RESULTS

..............................................................................................................

EXIT MEETINGS AND DEBRIEFS

............................................................................................ 6

DOCUMENTS REVIEWED

.......................................................................................................... 7

INSPECTION SCOPE

Inspections were conducted using the appropriate portions of Temporary Instruction (TI)

procedure 2515/191, Implementation of Mitigation Strategies and Spent Fuel Pool (SFP)

Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose

Assessment Plans, (ADAMS Accession No. ML18191B074). Documents reviewed by

inspectors are listed in the documents reviewed section of this report. 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.

OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

TI 2515/191 - Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool

Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose

Assessment Plans

Inspectors verified plans for complying with NRC Orders EA-12-049, Order Modifying

Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis

External Events, (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML12056A045) and EA-12-051, Order Modifying Licenses with Regard to

Reliable Spent Fuel Pool Instrumentation, (ML12054A679) were in place and were being

implemented by the licensee. Additionally, the inspection verified implementation of staffing and

communications information provided in response to the March 12, 2012, request for

information letter (ML12053A340) and dose assessment information provided per COMSECY-

13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons

Learned, dated March 27, 2013 (ML12339A262).

(1) Based on samples selected for review, the inspectors verified that the licensee

satisfactorily implemented appropriate elements of the Diverse and Flexible Coping

Strategies (FLEX) as described in the plant-specific submittals and the associated safety

evaluation (ML17090A457) and determined that the licensee is in compliance with NRC

Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation

Strategies for Beyond-Design-Basis External Events (ML12056A045). The inspectors

verified the licensee satisfactorily:

a) developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX

strategies for postulated external events;

b) integrated their FSGs into their existing plant procedures such that entry into and

departure from the FSGs were clear when using existing plant procedures;

c) protected FLEX equipment from site-specific hazards;

d) developed and implemented adequate testing and maintenance of FLEX equipment

to ensure their availability and capability;

e) trained their staff to ensure personnel proficiency in the mitigation of

beyond-design basis events; and

f) developed the means to ensure the necessary off-site FLEX equipment would be

available from off-site locations.

(2) Based on samples selected for review, the inspectors verified that the licensee

satisfactorily implemented appropriate elements of the FLEX strategy as described in the

plant specific submittals and the associated safety evaluation (ML17090A457) and

determined that the licensee was in compliance with NRC Order NRC Order EA-12-

051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool

Instrumentation (ML12054A679). The inspectors verified that the licensee satisfactorily:

a) installed the spent fuel pool (SFP) instrumentation sensors, cabling and power

supplies to provide physical and electrical separation as described in the plant

specific submittals and safety evaluation;

b) installed the SFP instrumentation display in the location, environmental conditions

and accessibility as described in the plant specific submittals;

c) trained their staff to assure personnel proficiency with the maintenance, testing, and

use of the SFP instrumentation; and

d) developed and issued procedures for maintenance, testing and use of the reliable

SFP instrumentation.

(3) The inspectors reviewed information provided in the licensees dose submittal and in

response to the NRCs March 12, 2012, request for information letter (ML12053A340),

and verified that the licensee satisfactorily implemented enhancements pertaining to

Near-Term Task Force (NTTF) Recommendation 9.3 response to a large-scale natural

emergency event that results in an extended loss of all alternating current (ac) power

(ELAP) to all site units and impedes access to the site The inspectors verified the

following:

a) the licensee satisfactorily implemented required staffing changes to support a

ELAP scenario;

b) emergency preparedness (EP) communications equipment and facilities are

sufficient for dealing with a ELAP scenario; and

c) the licensee implemented dose assessment capabilities (including releases from

SFPs) using the licensees site-specific dose assessment software and approach.

The inspectors verified that noncompliances with requirements, and standards identified during

the inspection were entered into the licensee's corrective action program as appropriate.

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

No proprietary information was retained by the inspectors or documented in this report.

On June 28, 2018, the inspectors presented the inspection results to Mr.

D. Erb, Acting Plant

Manager, and other members of the licensees staff.

On July 19, 2018, the lead inspector presented the final inspection results to Mr.

G. Surber,

Licensing Manager.

DOCUMENTS REVIEWED

Condition Reports Initiated as a Result of the Inspection

10509209, NRC Identified - Unit 1 PRIMARY SFP LI (N1G31LI0007) Red Light on UPS

Illuminated

10509496, During NRC Walk-down in FLEX Dome, One Section of Rolled Hose Had Tight

Radius Bend

10509705, Alternate SFP Level Indicators for FLEX are not Operable

10509712, Procedure FNP-1-SOP-36.4A Page 31, Breaker #9 Description Needs to Read

N1G31LI0008/ N2G31LI0008

10509720, Procedure FNP-1-SOP-36.4A Page 29, Breaker #9, Delete Entire Entry (Does Not

Exist)

10509764, Procedures for PRIMARY and ALT SFP LI Need Enhancements to Address

Abnormal Indications

10509896, Fleet Documents for Common SFP LI Not Consistent Across Fleet

10510217, NRC Identified - Perform Training Needs Analysis for Functionality Assessment of

FLEX Equipment

10510402, NRC Identified - Editorial Error in SNC Response to NRC Request for Information

10510406, NRC Identified - Evaluate Enhancing FNP-0-AOP-21 to add FLEX Dome Cold

Weather Actions

Procedures

FNP-0-AOP-21.0, Farley Nuclear Plant Abnormal Operating Procedure Severe Weather,

Revision (Rev.) 46.1

FNP-1-ECP-0.0, Unit 1 Loss of All AC Power, Rev. 30.0

FNP-2-ECP-0.0, Unit 2 Loss of All AC Power, Rev.30.0

FNP-1-IMP-222.0, Unit 1 Spent Fuel Pool Level Instrumentation Calibration, Version (Ver.) 1.0

FNP-2-IMP-222.0, Unit 2 Spent Fuel Pool Level Instrumentation Calibration, Ver. 1.0

FNP-1-SOP-54.0, Spent Fuel Pit Cooling & Purification System, Ver. 75.1

FNP-2-SOP-54.0, Spent Fuel Pit Cooling & Purification System, Ver. 75.0

FNP-1-SOP-36.4A, 120V AC Distribution Systems - AUX BLDG, Rev. 32

FNP-2-SOP-36.4A, 120V AC Distribution Systems Auxiliary Building, Rev. 34

NMP-EP-147, Offsite Dose Assessment, Ver. 2.0

NMP-GM-038, Diverse and Flexible Coping Strategies (FLEX) Program, Ver. 2.0

NMP-OM-002, Shutdown Risk Management, Ver. 5.0

NMP-OS-007-001, Conduct of Operations Standards and Expectations, Ver. 16.2

NMP-OS-019-001, EOF Support for Beyond Design Basis Events, Ver. 3.0

NMP-OS-019-002, Farley Nuclear Plant TSC Options, Ver. 3.0

NMP-OS-017, Severe Weather, Ver. 1.1

NMP-OS-019-013, Unit S, Beyond Design Basis Equipment Unavailability Tracking, Ver. 2.0

NMP-OS-019-100, Unit S Flex Portable Equipment Operating Instructions, Ver. 1.0

NMP-OS-019-111, Farley Unit 1 FSG-11, Alternate SFP Makeup and Cooling, Ver. 1.1

NMP-OS-019-112, Farley Unit 1 FSG-12, Alternate Containment Cooling, Ver. 2.0

NMP-OS-019-103, Unit 1 FSG-3, Alternate Low Pressure Feedwater, Ver. 1.0

NMP-OS-019-123, Unit 2 FSG-3, Alternate Low Pressure Feedwater, Ver. 1.0

NMP-OS-019-104, Unit 1 FSG-4, ELAP DC Load Shed/Management, Ver. 2.0

NMP-OS-019-124, Unit 2 FSG-4, ELAP DC Load Shed/Management, Ver. 2.0

NMP-OS-019-105, Unit 1 FSG-5, Initial Assessment and FLEX Equipment Staging, Ver. 1.2

NMP-OS-019-125, Unit 2 FSG-5, Initial Assessment and FLEX Equipment Staging, Ver. 2.1

NMP-OS-019-114, Unit 1 FSG-14 Shutdown Modes, Ver. 1.1

NMP-OS-019-134, Unit 2 FSG-14 Shutdown Modes, Ver. 1.1

NMP-OS-019-159 Unit S SIG-9, Communications, Ver. 1.0

NMP-OS-019-165, Unit 1 SIG-5, Tank Makeup, Ver. 1.1

NMP-OS-019-108, Farley Unit 1 FSG-8, Alternate RCS Boration, Ver. 1.1

NMP-OS-019-161, Farley Unit S SIG-1 600V Alternate Power, Ver. 2.1

NMP-OS-019-162, Farley Unit S SIG-2 480V Alternate Power, Ver. 1.1

NMP-OS-019-164, Farley Unit 1 SIG-4, Boron Injection and RCS Makeup, Ver. 2.1

NMP-OS=019-166, Farley Unit 1 SIG-6, Containment Integrity, Ver. 1.0

NMP-OS-019-157, Farley Unit S SIG-7, Diesel Fuel Oil Transfer, Ver. 2.1

NMP-OS-019-131, Farley Unit 2 FSG-11, Alternate SFP Makeup and Cooling, Ver. 1.1

NMP-OS-019-151, Farley Unit S FSG-11 Background Document, Ver. 1.0

NMP-OS-019-158, Farley Unit S SIG-8, Spent Fuel Pool Makeup, Ver. 1.1

NMP-OS-019-163, Farley Unit 1 SIG-3, Core Cooling, Ver. 1.1

NMP-OS-019-183, Farley Unit 2 SIG-3, Core Cooling, Ver. 2.1

TRNOPS-TR-417-001, Plant Farley Initial License Training Program Instruction, Ver. 1.0

TRNOPS-TR-415-001, Plant Farley Systems Operator Training Program Instruction

Drawings

A181108, 8.6, Flow Schematic, Ver. 3.0

A181105, 8.1, Flow Schematic, Ver. 2.0

A181106, 8.1, Flow Schematic, Ver. 4.0

A181125, Attachment A, Ver. 1.0

A181115, Site Plot Plan, Ver. 2.0

A181115, Partial Plot Plan, Ver. 2.0

A181106, FLEX Portable System, Spent Fuel Pool Subsystem, Phase 2, Ver. 4.0

D-177001, Single Line Electrical Auxiliary System Emergency 4160 & 600V Worksheet

SNC467063E002, Ver. 2.0

Work Orders

SNC878108, Unit S Flex Communication Modem Replacement

SNC894667, FLEX storage Building (Dome) Standby Walk-down, Rev. 0

SNC913263, Battery is not charging for Unit 2 ALT SFP LI (N2G31LI0008), dated February 8,

2018

SNC872887, Replace Batteries for Unit 2 ALT SFP LI (N2G31LI0008), dated December 11,

2017

SNC874015, Replace Batteries for Unit 2 PRIMARY SFP LI (N2G31LI0007), dated August 4,

2017

SNC824684, Replace Batteries for Unit 2 ALT SFP LI (N2G31LI0008), dated June 9, 2017

SNC824683, Replace Batteries for Unit 1 ALT SFP LI (N1G31LI0008), dated June 9, 2017

SNC871306, SG FLEX Pump Functional Test and Inspection

SNC830921, SG FLEX Pump Operational Inspection

SNC779173, Boron Injection FLEX Pump Skid Operational Inspection

SNC871318, 600V FLEX Diesel Generator Functional Test and Inspection

SNC872281, 600V FLEX Diesel Generator Operational Inspection

SNC829882, 600V FLEX Diesel Generator Functional Test and Inspection

SNC829871, SG FLEX Pump Functional Test and Inspection

Condition Reports

10345426

263652

290610

292439

296763

297515

10133337

10345426

10353387

10357521

10509542

10509702

10076939

10076943

10095022

260819

263553

292907

292440

292441

10301430

10370275

10370351

10372991

10372995

10374860

10375223

10437010

10439000

10477767

10477769

10496998

10494961

280106

10424345

261671

10453055

281806

10382284

10493500

10373488

232249

257129

244627

296763

Other

A181163, Flex Portable System Steam Generator FLEX Pump Vendor Manual, Ver. 1.0

A181102, Att. A, Phase 2 480V and 600V Alternating Power Subsystem, Ver. 3.0

Enercon Project No: SNCF206, Report of Liquefaction Potential Assessment

RapidCase Functional Test and Inspection Work Instructions

Flex Training Records for System Operators and Licensed Operators

RER SNC 546909-02

NEI 12-01 Farley On-Shift Staffing Analysis, Ver.2.0

SNC Dose Assessment Form - Plant Farley, June 27, 2018 - 0730

NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and

Communications Capabilities, Rev. 0

NEI-12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide Rev. 2

Fukushima Response NEI 12-01 On-Shift Staffing Analysis Phase 2 Report Version 2.0

Standard Emergency Plan, Ver.2.0

FHC-S-13-001/X1AR50, Flex Equipment Storage Building, Ver. 2.0

Southern Nuclear Operating Company Letter (NL-13-0987), Joseph M. Farley Nuclear Plant -

Units 1 & 2, Edwin

I. Hatch Nuclear Plant - Units 1 & 2, Vogtle Electric Generating Nuclear

Plant - Units 1& 2, Capability to Perform Emergency Multi-Unit Offsite Dose Assessments,

dated June 24, 2013

U612262, Spent Fuel Pool Instrumentation System Standard Product Technical Manual,

Ver. 1.0

NMP-TR-212-F08, Training Needs Analysis, F-LT-NL-2014050, dated august 22, 2014

Adams Accession Number ML15182A175, Letter NL-15-0699, Joseph

M. Farley, Unit 1 -

Completion of Required Action by NRC Order EA-12-051, Reliable Spent Fuel Pool Level

Instrumentation, dated June 26, 2015

Adams Accession Number ML14239A328, Letter NL-14-1109, Joseph

M. Farley, Units 1 and 2

- Third Six-Month Status Report of the Implementation of the Requirements of the

Commission Order with Regard to Reliable Spent Fuel Pool Level Instrumentation (EA-12-

051), dated August 26, 2014

RER SNC56909, RER for FLEX Storage Building Site Evaluation and Documentation, Ver. 1.1

SNC Standard Emergency Plan Annex for FNP Units 1 and 2, Ver. 1.0

Diesel Fuel Supply Assurance Letter, dated June 27, 2018

SAFER Response Plan for Joseph

M. Farley Generating Station, Rev. 1

Documentation of Engineering Judgement, DOEJ-FDSNC467063-E001, Voltage Drop Cable

Sizing, and Train Separation Evaluation for Flex Power Cables for 600V Buses 1D, 1E, 2D,

and 2E, Ver. 3.0

A-181103, Flex Portable System Phase 3 4160V Alternate Power System, Ver. 2.0

Calculation SM-SNC458207-006, Auxiliary Building El. 100 Corridor Heat up Evaluation during

an Extended Loss of all AC Power ELAP, Ver. 1.0

Joseph

M. Farley, Units 1 and 2, Safety Evaluation Regarding Implementation of Mitigating

Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and

EA-12-051 (CAC Nos. MF0716, MF0717, MF1429 and MF1430), dated April 24, 2017

Final Integrated Plan,

U. S. Nuclear Regulatory Commission Order EA-12-049, Strategies for

Beyond Design Basis External Events, November 2016

Farley Nuclear Plant Flex Validation Report, dated April 27, 2016

Plant Farley FLEX Overview NRC TI-191 Inspection, dated June 25, 2018

SNCF166-PR-002, Diverse and Flexible Coping Strategies (FLEX) in Response to NRC Order

EA-12-049 Mitigating Strategies for Beyond-Design -Bases External Events, Rev. 3

Fukushima Response, NEI-12-01, On-Shift Staffing Analysis Phase 2 Report, Ver. 2.0