IR 05000259/2019003

Integrated Inspection Report 05000259/2019003, 05000260/2019003, and 05000296/2019003

ML19303C165
Person / Time
Site:	Browns Ferry
Issue date:	10/29/2019
From:	Omar Lopez-Santiago NRC/RGN-II/DRP/RPB5
To:	Jim Barstow Tennessee Valley Authority
Geanette D
References
IR 2019003
Download: ML19303C165 (20)

Text

October 29, 2019

SUBJECT:

BROWNS FERRY NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000259/2019003 AND 05000260/2019003 AND 05000296/2019003

Dear Mr. Barstow:

On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Browns Ferry Nuclear Plant. On October 25, 2019, the NRC inspectors discussed the results of this inspection with Steven M. Bono, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.

Two Severity Level IV violations without an associated finding are documented in this report.

We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or significance or severity of the violations 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 Browns Ferry. 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.

Sincerely,

/RA/

Omar R. López-Santiago, Chief Reactor Projects Branch 5 Division of Reactor Projects

Docket Nos. 05000259 and 05000260 and 05000296 License Nos. DPR-33 and DPR-52 and DPR-68

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000259, 05000260 and 05000296

License Numbers:

DPR-33, DPR-52 and DPR-68

Report Numbers:

05000259/2019003, 05000260/2019003 and 05000296/2019003

Licensee:

Tennessee Valley Authority

Facility:

Browns Ferry Nuclear Plant

Location:

Athens, Alabama

Inspection Dates:

July 01, 2019 to September 30, 2019

Inspectors:

N. Hobbs, Resident Inspector

M. Kirk, Resident Inspector

P. Meier, Senior Resident Inspector

S. Monarque, Project Engineer

T. Stephen, Senior Resident Inspector

Approved By:

Omar R. López-Santiago, Chief

Reactor Projects Branch 5

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Browns Ferry 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

Unit 2 Main Steam Relief Valves (MSRVs) Lift Outside of Technical Specifications Limits Cornerstone Significance Cross-Cutting Aspect Report Section Not Applicable NCV 05000260/2019003-01 Open/Closed Not Applicable 71153 A self-revealed Severity Level IV Non-cited Violation (NCV) of Technical Specification (TS)3.4.3 was identified when the licensee discovered, through as found test results, that four of the 13 MSRVs that were removed for testing had as found lift settings outside of the +/- 3 percent band required for their operability. One was removed during a Spring 2018 forced outage and the other 12 were removed during the Spring 2019 refueling outage.

Unit 2 Traversing In-core Probe Purge Header Check Valve Leak Rate in Excess of Technical Specifications Limits Cornerstone Significance Cross-Cutting Aspect Report Section Not Applicable NCV 05000260/2019003-02 Open/Closed Not Applicable 71153 A self-revealed Severity Level IV NCV of TS 3.6.1.3, Primary Containment Isolation Valves (PCIVs) was identified when the licensee determined that the traversing in-core probe (TIP)header check valve was inoperable for longer than the allowed outage time.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000296/2019001-04 Unit 3 Notice of Unusual Event (NOUE) Caused by a Loss of Offsite Power (LOOP) Resulting in a Reactor Scram 71152 Closed LER 05000260/2019-001-00 LER 2019-001-00 for Browns Ferry Nuclear Plant,

Unit 2, Traversing In-core Probe Purge Header Check Valve Leak Rate in Excess of Technical Specifications Limits.

71153 Closed LER 05000260/2019-002-00 LER 2019-002-00 for Browns Ferry Nuclear Plant Unit 2, Main Steam Relief Valves Lift Settings Outside 71153 Closed of Technical Specifications Required Setpoints.

LER 05000296/2019-001-01 LER 296/2019-001-01 for Browns Ferry Nuclear Plant,

Unit 3, Automatic Reactor Scram Due to a Turbine Load Reject 71153 Closed

PLANT STATUS

Unit 1 operated at or near Rated Thermal Power (RTP) until August 19, 2019 when the unit was down powered to approximately 50 percent power for river thermal compliance after the loss of cooling towers resulting from a lightning strike. Cooling Towers were restored and the unit returned to RTP on August 20, 2019 and remained there for the rest of the inspection period.

Unit 2 operated at or near RTP until August 19, 2019 when the unit was down powered to approximately 50 percent power for river thermal compliance after the loss of cooling towers resulting from a lightning strike. Cooling Towers were restored and the unit returned to RTP on August 21, 2019 and remained there until September 21, 2019 when the unit was shutdown for a planned outage to make repairs to condensers. The unit was restarted late on September 30, 2019.

Unit 3 operated at or near RTP until August 19, 2019 when the unit was down powered to approximately 70 percent power for river thermal compliance after the loss of cooling towers resulting from a lightning strike. Cooling Towers were restored and the unit returned to RTP on August 20, 2019 and remained there for the rest of the inspection period.

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 performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.

71111.01 - Adverse Weather Protection

External Flooding Sample (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated readiness to cope with external flooding on September 19, 2019.

71111.04Q - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 2 Loop 2 Residual Heat Removal while Loop 1 was out of service on August 27, 2019.

(2) Units 1 and 2, B Control Bay Chiller with A Control Bay Chiller inoperable due to degraded conditions on September 6, 2019.

71111.05Q - Fire Protection

Quarterly Inspection (IP Section 03.01) (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Unit 3, Fire Area 19, Unit 3 Battery and Battery Board Room on August 20, 2019.

(2) Unit 1, Fire Area 5, Electric Board Room 1A, including 250V Battery Rooms on August 28, 2019.

(3) Units 2 and 3, Fire Area 16-A, Cable Spreading Room B on August 28, 2019.

(4) Unit 1, Fire Area 01-03, Reactor Building Elevation 593 feet North on August 29, 2019.

(5) Unit 2, Fire Area 02-03, Reactor Building Elevation 593 feet North on August 29, 2019.

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Unit 3 Diesel Generator (DG) Building on September 6, 2019.

71111.07A - Heat Sink Performance

Annual Review (IP Section 02.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Unit 3, 3A DG Coolers 3A1 and 3A2 on August 14, 2019.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the Control Room during Unit 2 shutdown and cooldown from September 20-21, 2019.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a license operator requalification simulator exercise on July 18, 2019.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness Inspection (IP Section 02.01) (2 Samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Units 1, 2, and 3, Screening of the Emergency High Pressure Makeup (EHPM)pumps into the Maintenance Rule.

(2) Unit 3, Function 078-C, Reactor Water Cleanup Area Temperature Indication (a)(1)

Evaluation.

Quality Control (IP Section 02.02) (1 Sample)

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance activities:

(1) Calibration, control and deficient equipment processes for Measuring and Test Equipment used for safety related systems.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Elevated site risk on July 16, 2019, due to Unit 2 HPCI surveillance, B Standby Gas maintenance, and the Spent Fuel Pool cleanout project.

(2) Elevated risk during the week of July 29 to August 2, due to 3A DG extended outage, Unit 3 preferred AC power loss, and a Conservative Operations Alert.

(3) Elevated site risk during the week of August 12 to 16, 2019, due to 480V Load Shed Logic testing on Units 1 and 2 during a Conservative Operations Alert.

(4) Emergent site risk associated with the inability to access the remote shutdown panels on Units 1 and 3 due to a lightning strike on September 10, 2019. (EN 54266)

(5) Elevated site risk on September 16, 2019, due to 3C DG extended maintenance outage during a Conservative Operations Alert.

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 02.02) (6 Samples)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 3, Functional Evaluation for 3B Electric Board Room Chiller on August 16, 2019.

(2) Units 1 and 2, Operability evaluation for Common Accident Signal Logic relays which failed acceptance criteria on July 24, 2019.

(3) Unit 2, Functionality evaluation for 2B Drywell Equipment Drain Sump Pump following trips due to thermal overload on July 13, 2019.

(4) Unit 2, Past Operability Evaluation for the High Pressure Coolant Injection (HPCI) steam line inboard isolation valve failing to coast to its backseat on March 2, 2019.

(5) Units 1 and 2, Operability evaluation for failure to meet an acceptance criteria for the 480V Load Shedding Logic System Functional Test on August 14, 2019.

(6) Unit 3, Operability evaluation of 3D Diesel Generator output breaker failing to close on September 18, 2019.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the following post maintenance tests:

(1) Units 1, 2, and 3, B Standby Gas Treatment (SBGT) surveillance following maintenance on July 20, 2019.

(2) Unit 1, Post maintenance testing (PMT) of Core Spray (CS) Loop I motor operated valve breakers and time delay relay replacements following planned preventative maintenance the week of July 9, 2019.

(3) Unit 2, Review of EPU Test Data associated with TI-131, Feedwater Level Control System.

(4) Unit 3, PMT of Emergency Diesel Generator (EDG) 3A following biennial maintenance during the week of August 5, 2019.

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Partial)

(1)

(Partial)

Unit 2 forced outage for main condenser tube leak repair from September 20 to September 30, 2019. The residents observed unit shutdown, drywell closeout, Foreign Material Exclusion (FME) controls. The unit transitioned to Mode 2 (Startup) shortly before midnight on September 30, 2019. The inspection of this outage will be completed in the fourth quarter of 2019.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Reactor Core Isolation Cooling (RCIC) System rated flow surveillance on July 10, 2019.

(2) Unit 2, HPCI System rated flowrate surveillance on July 16, 2019.

(3) Units 1 and 2, 480V Load Shedding Logic System Functional test (Division II) on August 13-16, 2019.

(4) Units 1, 2 and 3, 0-SI-4.5.C.1(A3) - RHRSW Pump A3 Inservice Test (IST) Group A Quarterly Pump Test Increased Frequency on July 15, 2019.

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) Unit 3 Emergency Plan drill conducted with the plant initially in Mode 4 on August 7,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS06: Emergency AC Power Systems (IP Section 02.05)===

(1) Unit 1 (July 1, 2018 - June 30, 2019)

(2) Unit 2 (July 1, 2018 - June 30, 2019)

(3) Unit 3 (July 1, 2018 - June 30, 2019)

MS09: Residual Heat Removal Systems (IP Section 02.08) (3 Samples)

(1) Unit 1 (July 1, 2018 - June 30, 2019)

(2) Unit 2 (July 1, 2018 - June 30, 2019)

(3) Unit 3 (July 1, 2018 - June 30, 2019)

MS10: Cooling Water Support Systems (IP Section 02.09) (3 Samples)

(1) Unit 1 (July 1, 2018 - June 30, 2019)

(2) Unit 2 (July 1, 2018 - June 30, 2019)

(3) Unit 3 (July 1, 2018 - June 30, 2019)

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Root Cause for CR 1497448 Unit 3 Turbine Load Reject Scram, Revision 1. This is the final inspection needed to close URI 05000296/2019001-04 Unit 3 Notice of Unusual Event (NOUE) Caused by a Loss of Offsite Power (LOOP) Resulting in a Reactor Scram.

(2) The inspectors reviewed the licensees implementation of its corrective action program related to Problem Identification & Resolution associated with Unit 2 Extended Power Uprate.

71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000260/2019-002-00 Main Steam Relief Valves Lift Settings Outside of Technical Specifications Required Setpoints (ADAMS accession: ML19199A333)

The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The circumstances surrounding this LER are documented in the Results Section.

(2) LER 05000296/2019-001-01 Automatic Reactor Scram Due to a Turbine Load Reject (ADAMS accession: ML19189A125)

The inspectors reviewed the updated LER submittal. No additional findings or violations were identified. The previous LER submittal was reviewed in Inspection Report 05000259, 260, 296/2019-002.

(3) LER 05000260/2019-001-00 Traversing In-core Probe Purge Header Check Valve Leak Rate in Excess of Technical Specifications Limits (ADAMS accession:

ML19142A361)

The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The circumstances surrounding this LER are documented in the Results Section.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

===71004 - Power Uprate

Summary of Power Uprate Inspection Samples Contained in this Report:

Identification and Resolution of Problems (Unit 2)===

(1) Problem Identification and Resolution related to EPU (Section 71152)

INSPECTION RESULTS

Unresolved Item (Closed)

Unit 3 Notice of Unusual Event (NOUE) Caused by a Loss of Offsite Power (LOOP) Resulting in a Reactor Scram URI 05000296/2019001-04 71152

Description:

The loss of excitation on the Auto-Voltage Regulator (AVR) on the Browns Ferry Unit 3 Main Generator caused the main generator output and 500kV switchyard breakers to open due to a sudden increase in output current. Additional inspection was required to determine if there were performance deficiencies associated with this event. The review of the LER associated with this event was documented in Browns Ferry Integrated Inspection Report 05000259, 260, 296/2019002 (ML19224B824) as a Green Finding (05000296/2019002-01). All three of the required inspections for this issue have been completed and this URI is now closed.

Corrective Action Reference(s): Condition Report 1497448

Unit 2 Traversing In-core Probe Purge Header Check Valve Leak Rate in Excess of Technical Specifications Limits Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000260/2019003-02 Open/Closed

Not Applicable 71153 A self-revealed Severity Level IV Non-cited Violation (NCV) of Technical Specification (TS) 3.6.1.3, Primary Containment Isolation Valves (PCIVs) was identified when the licensee determined that the traversing in-core probe (TIP) header check valve was inoperable for longer than the allowed outage time.

Description:

The licensee submitted LER 05000260/2019-001-00 which was associated with a Unit 2 local leak rate test failure of a primary containment penetration for the TIP system. This issue was discovered on March 23, 2019 while performing a required surveillance test (SR) prior to the restart of the unit following the refueling outage. Troubleshooting determined that the TIP purge header check valve, 2-CKV-76-653, was leaking by such that the test volume could not be pressurized for penetration X-35F. This was an indication that the valve was likely stuck in the open position. The licensee performed a cause evaluation and determined that the apparent failure mechanism for the valve being in the stuck open position was due to debris in the valve body. The licensee determined that the TIP purge header check valve was inoperable from March 31, 2017 (beginning of cycle) to March 2, 2019 (beginning of refueling outage). The inspectors reviewed the licensee event report and determined that the report adequately documented the summary of the event including the cause and the potential safety consequences. The inspectors also reviewed other licensee documents, including past surveillance's, work orders and condition reports to determine if there were any performance deficiencies associated with this event.

Corrective Actions: The licensee replaced the failed check valve on March 31, 2019 and successfully tested the valve in accordance with the requirements. The licensee has corrective actions to implement a design change to all three units. This design change will add an additional check valve in series to provide duel barrier containment isolation.

Corrective Action References: CR 1501555

Performance Assessment:

The NRC determined this violation was not reasonably foreseeable and preventable by the licensee and therefore is not a performance deficiency.

Enforcement:

The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance. Traditional Enforcement is being used in accordance with the Interim Guidance for Dispositioning Severity Level IV Violations with No Associated Performance Deficiencies (ML18158A220).

Severity: This violation is characterized as a Severity Level IV NCV based on its similarity to SLIV example 6.1.d.1 in the Enforcement Policy.

Violation: Browns Ferry Nuclear Plant, Unit 2 TS Subsection 3.6.1.3, 'Primary Containment Isolation Valves (PCIVs),' Condition C, required that with one or more penetration flow paths with one PCIV inoperable, that the flow path be isolated within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Condtion E requires that the unit be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> if Condition C is not met. Contrary to the above, 2-CKV-76-653, TIP purge header check valve, was inoperable from March 31, 2017 to March 2, 2019. The flow path was not isolated within four hours, and the unit did not enter Mode 3 and Mode 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, respectively, for failing to meet Condition C.

Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Unit 2 Main Steam Relief Valves (MSRVs) Lift Outside of Technical Specifications Limits Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000260/2019003-01 Open/Closed

Not Applicable 71153 A self-revealed Severity Level IV NCV of TS 3.4.3 was identified when the licensee discovered, through as found test results, that four of the 13 MSRVs that were removed for testing had as found lift settings outside of the +/- 3 percent band required for their operability. One was removed during a Spring 2018 forced outage and the other 12 were removed during the Spring 2019 refueling outage.

Description:

The Browns Ferry Unit 2 TS 3.4.3 required 12 of the 13 MSRVs to be operable while in Modes 1, 2, and 3. On May 29, 2019, the Tennessee Valley Authority was notified of as-found testing results that three Main Steam Relief Valves (MSRVs) from Unit 2 were outside the +/- 3 percent setpoint band required for operability. It was determined that these MSRVs failed due to corrosion bonding to the valve seat as a result of its platinum anti-corrosion coating flaking off. Previously, on April 27, 2018, MSRV BFN-2-PCV-001-0041 had been declared inoperable due to excessive leakage. Failure of this MSRV was caused by a delamination of a portion of the platinum anti-corrosion coating which led to the leak. More than one MSRV was considered to be inoperable during the entire operating cycle and longer than permitted by Technical Specifications. The affected valves remained capable of maintaining reactor pressure within American Society of Mechanical Engineers code limits. All thirteen of the MSRV pilot valves have been replaced during the Unit 2 Spring 2019 refueling outage. The previous corrective action from LER 50-259/2018-007-00 to perform nitrogen leak testing prior to platinum coating had not yet been implemented for these valves.

This continues to be the corrective action to prevent recurrence. In addition, an improved method of applying the platinum to the pilot discs will now be used which provides a more consistent and forgiving finish on the pilot valve seating surface.

Corrective Actions: The licensee replaced a leaking pilot valve on MSRV BFN-2-PCV-001-0041 during a Spring 2018 forced outage. The licensee replaced the other 12 MSRVs during the Spring 2019 refueling outage. The licensee has corrective actions to ensure that pilot discs are prepared for platinum coating in accordance with the revised procedure and vendor recommendations. The currently installed refurbished valves had platinum coatings applied in accordance with the revised procedure, and as-left values were verified to be within +/- one percent of their setpoints.

Corrective Action References: CRs 1286467, 1410577, and 1521190.

Performance Assessment:

The NRC determined this violation was not reasonably foreseeable and preventable by the licensee and therefore is not a performance deficiency.

Enforcement:

The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance. Traditional Enforcement is being used in accordance with the Interim Guidance for Dispositioning Severity Level IV Violations with No Associated Performance Deficiencies (ML18158A220).

Severity: This violation is characterized as a Severity Level IV NCV based on its similarity to SLIV example 6.1.d.1 in the Enforcement Policy.

Violation: Browns Ferry Nuclear Plant, Unit 2 TS Subsection 3.4.3, 'Safety/Relief Valves (S/RVs),' Condition A, required that with one or more required S/RVs inoperable, that the unit be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Contrary to the above, three required S/RVs were inoperable from March 29, 2017 to March 2, 2019, and the unit did not enter Mode 3 and Mode 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, respectively.

Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On October 25, 2019, the inspectors presented the integrated inspection results to Steven M. Bono, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.01

Corrective Action

Documents

CR 1425000,

1478269, 1544189

Procedures

0-AOI-100-3

Flood Above Elevation 558'

Revision 48

MPI-0-000-INS001

Inspection of Flood Protection Devices

Revision 17

71111.04Q Drawings

0-021021-PD-1

Liquid Chiller

Revision 1

2-47E811-1-NFPA805 NFPA 805 Flow Diagram Residual Heat Removal

System

Revision 001

Procedures

0-GOI-300-1/ATT-11

11 Control Bay Operator Round Log

Revision 235

0-OI-31

Control Bay and Off-Gas Treatment Building Air

Conditioning System

Revision 155

2-OI-74/Attachment 1

Valve Lineup Checklist Unit 2

Revision 142

2-OI-74/Attachment 3

Electrical Lineup Checklist

Revision 142

71111.05Q Procedures

FPR-Volume 2

Fire Protection Report Volume 2

Revision 65

71111.06

Calculations

NDN00099920070031 BFN Probabilistic Risk Assessment - Internal Flooding

Analysis

Revision 2

Corrective Action

Documents

CR 1544094

Drawings

3-47W587-1

Mechanical Drains & Embedded Piping

Revision 4

71111.07A

Calculations

MDQ0082000016

Diesel Generator Jacket Water Cooler Capacity and

Tube Plugging

Revision 2

Engineering

Evaluations

Eddy Current Examination Results for Diesel Generator

Coolers 3A1 and 3A2

Procedures

0-TPP-ENG-389

Raw Water Fouling and Corrosion Control

Revision 3

MCI-0-082-CLR001

Standby Diesel Engine Water Coolers Disassembly,

Inspection, Rework, and Reassembly

Revision 40

Work Orders

WO 120001166

71111.11Q Miscellaneous

OPL175S432

Procedures

NPG-SPP-17.8.3

Simulator Exercise Guide Development and Revision

Revision 9

NPG-SPP-17.8.4

Conduct of Simulator Operations

Revision 6

NPG-SPP-22.206

Verification Program

Revision 5

OPDP-1

Conduct of Operations

Revision 44

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.12

Corrective Action

Documents

CR 153249, 1531960,

1533447, 1536857,

1536866, 1536867,

1536869, 1536870

Engineering

Evaluations

Evaluation of EHPM pump system requiring entry into

the Maintenance Rule Program

Revision 0

Miscellaneous

Unit 3 RWCU Area Temperature Indication (a)(1) Plan

Function 078-C

Revision 0

BFN-50-7007

Emergency High Pressure Makeup Pump System

Design Criteria Document

Revision 1

BFN-50-7069

Reactor Water Cleanup System Design Criteria

Document

Revision 11

Procedures

NPG-SPP-03.4

Maintenance Rule Performance Indicator Monitoring,

Trending and Reporting - 10CFR50.65

Revision 3

NPG-SPP-06.4

Measuring and Test Equipment

Revision 4

SII-0-MTE-00-001

Instrumentation and Controls Standards Lab M&TE Post-

Use Instruction

Revision 4

71111.13

Corrective Action

Documents

CR 1548094

hour event notification 54266 was made to the NRC

09/11/2019

Miscellaneous

EN 54266

Unanalyzed Condition Due to Lightning Strike

Revision 0

Procedures

1-AOI-100-2

Control Room Abandonment

Revision 23

1-FSS-16-2

UNIT 1 ABANDONMENT Control Building EL 593', 606',

617' and 635'

Revision 6

BFN-ODM-4.18

Protected Equipment

Revision 22

71111.15

Corrective Action

Documents

CR 1491145

CR 1532340

CR 1535101

CR 1541401,

1541460, 1541523

CR 1550275, CR

1509728, CR

261546

Drawings

3-45E766-16

Wiring Diagram 4160V Shutdown Aux Power Schematic

Diagram

Revision 21

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Engineering

Evaluations

CR 1541042

AC step not met during 0-SR-3.8.1.8(II)

EWR19EEB077116

Re-evaluate Thermal Overlaod Heater Size for 2-MTR-

077-00148, Drywell Equipment Drain Sump Pump 2B

07/16/2019

Operability

Evaluations

POE for CR 1494872

HPCI Steam Line inboard isolation valve failed to

backseat

Revision 0

Procedures

0-GOI-300-2

Electrical

Revision 156

0-SR-3.8.1.8(II)

480V Load Shedding Logic System Functional Test

(Division II)

Revision 18

3-SR-3.8.1.1(3D)

Diesel Generator 3D Monthly Operability Test

Revision 62

NPG-SPP-06.9.1

Conduct of Testing

Revision 12

OPDP-8

Operability Determination Process and Limiting

Conditions for Operation Tracking

Revision 25

Work Orders

WO 120799438, WO 20416768, WO 118504760

71111.19

Corrective Action

Documents

CR 1523831

CR 1533033

CR 1533448

Procedures

0-SR-3.6.4.3.1

Standby Gas Treatment System Train Operation

Revision 23

0-SR-3.6.4.3.2(B

VFTP)

Standby Gas Treatment Filter Pressure Drop and In-

Place Leak Tests - Train B

Revision 19

1-SR-3.3.5.1.5(CS I)

CSS Logic Time Delay Relay Calibration (Loop I)

Revision 12

1-SR-3.5.1.6(CS I)

Core Spray Flow Rate Loop I

Revision 23

ECI-0-000-BKR008

Testing and Troubleshooting of Molded Case Circuit

Breakers and Motor Starter Overload Relays

Revision 108

EPI-0-000-MCC001

Maintenance and Inspection of 480VAC and 250VDC

Motor Control Centers

Revision 84

MPI-0-000-ACT001

Preventative Maintenance for Limitorque Operators

Revision 55

Work Order 119700327

3-SR-3.8.1.1(3A) - Diesel Generator '3A' Monthly

Operability Test

Revision 0

Work Orders

119958290,

119959389,

116481308,

119958291,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

20527759,

119359982,

119696200

WO 119696881

WO 120151834

71111.22

Corrective Action

Documents

CR 1435016

CR 1531321

CR 1532964

CR 1533085

CR 1534084,

1513428

CR 1540726,

1540731, 1540733,

1541042, 1541414

Procedures

0-SR-3.8.1.8(II)

480V Load Shedding Logic System Functional Testing

(Division II)

Revision 18

2-SR-3.5.1.7

HPCI Main & Booster Pump Set Developed Head & Flow

Rate Test at Rated Reactor Pressure

Revision 81

2-SR-3.5.3.3

RCIC System Rated Flow at Normal Operating Pressure Revision 71

Work Orders

WO 119602977

WO 119698618

WO 120454005,

119596805,

119248500

71114.06

Miscellaneous

BFN August 2019 Training Drill package

Revision 0

71151

Miscellaneous

Maintenance hours records for Units 1, 2, and 3 Residual

Heat Removal Service Water and Emergency Equipment

Cooling Water systems

07/01/2018 -

06/30/2019

Run demand records for Units 1, 2, and 3 Residual Heat

Removal Service Water and Emergency Equipment

Cooling Water systems

07/01/2018 -

06/30/2019

Units 1,2 and 3 June Derivation Reports for Residual

Heat Removal Systems (PLE, UAI and URI)

07/01/2018 -

06/30/2019

Units 1,2 and 3 June MSPI Margin Reports for Residual

07/01/2018 -

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Heat Removal Systems

06/30/2019

71152

Corrective Action

Documents

CR 1497448 Unit 3 Turbine Load Reject Scram

Revision 1

CR 1497448 Unit 3 Turbine Load Reject Scram

Revision 0

CR 1497448

Root Cause Charter and progress reports from March

11, 2019 to June 22, 2019.

Procedures

NPG-SPP 22.300

Corrective Action Program

Revision 16