IR 05000259/2020004
| ML21028A218 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/28/2021 |
| From: | Tom Stephen NRC/RGN-II/DRP/RPB5 |
| To: | Jim Barstow Tennessee Valley Authority |
| References | |
| EA-20-135 IR 2020002, IR 2020004 | |
| Download: ML21028A218 (20) | |
Text
January 28, 2021
SUBJECT:
BROWNS FERRY NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000259/2020004, 05000260/2020004, 05000296/2020004, 07200052/2020002 AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Mr. Barstow:
On December 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Browns Ferry Nuclear Plant. On January 26, 2021, the NRC inspectors discussed the results of this inspection with Mr. Matthew Rasmussen, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Thomas A. Stephen, Chief Reactor Projects Branch #5 Division of Reactor Projects
Docket Nos. 05000259, 05000260, 05000296 and 07200052 License Nos. DPR-33, DPR-52 and DPR-68
Enclosure:
As stated.
Inspection Report
Docket Numbers:
05000259, 05000260, 05000296, and 07200052
License Numbers:
Report Numbers:
05000259/2020004, 05000260/2020004, 05000296/2020004 and
07200052/2020002
Enterprise Identifier: I-2020-004-0052 and I-2020-002-0084
Licensee:
Tennessee Valley Authority
Facility:
Browns Ferry Nuclear Plant
Location:
Athens, Alabama
Inspection Dates:
October 01, 2020 to December 31, 2020
Inspectors:
S. Downey, Senior Reactor Inspector
M. Kirk, Resident Inspector
D. Lanyi, Senior Operations Engineer
H. Lynn, Senior Health Physicist
M. Magyar, Reactor Inspector
A. Nielsen, Senior Health Physicist
C. Rapp, Senior Project Engineer
M. Riley, Reactor Inspector
J. Seat, Project Engineer (Lead)
C. Stott, Resident Inspector
Approved By:
Thomas A. Stephen, 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
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000260/2020010-01 Water Hammer Analysis for Unit 2 HPCI Turbine Exhaust Piping 71111.17T Closed EDG EA-20-135 Failure to Comply with 10 CFR 37 for the Protection of Disused Steam Dryer Pieces Stored in a Concrete Module 71124.08 Closed LER 05000259,05000260/20 20-001-01 LER 2020-001-01 for Browns Ferry Nuclear Plant,
Units 1 and 2, Manual Reactor Shutdown of Two Units on Decreasing Condenser Vacuum due to Eel Grass Intrusion 71153 Closed LER 05000259,05000260/20 20-001-00 LER 2020-001-00 for Browns Ferry Nuclear Plant,
Unit 1 re Manual Reactor Shutdown of Two Units on Decreasing Condenser Vacuum due to Eel Grass Intrusion 71153 Closed
PLANT STATUS
Unit 1 began the inspection period in the end of cycle coast down at approximately 85 percent rated thermal power (RTP). On October 2, 2020, the unit was shut down for a planned refueling outage. Unit 1 entered Mode 1 on November 4, 2020, and was shut down on November 5, 2020, to address an Electrohydraulic Control (EHC) leak and elevated Main Turbine vibrations.
The Unit entered Mode 1 again on November 7, 2020 and achieved 85 percent RTP on November 9, 2020. The Unit remained at 85 percent RTP until December 6, 2020, when power was reduced to 60 percent RTP for implementation of a temporary modification to a recirculation flow sensing element. Unit 1 achieved RTP on December 10, 2020, where it remained through the end of the inspection period.
Unit 2 operated at or near RTP for the entire inspection period.
Unit 3 began the inspection period at 100 percent RTP. On December 10, 2020, Unit 3 power was reduced to 50 percent RTP for planned condenser tube maintenance. Unit 3 returned to RTP on December 13, 2020, where it remained through the end 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 reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the Coronavirus Disease 2019 (COVID-19),resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather associated with Hurricane Zeta on October 28, 2020.
External Flooding Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on November 18, 2020.
71111.04 - 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 1, Reactor water level instrumentation during 1R13 (refueling outage) on October 4, 2020
- (2) Unit 3, Train B control bay chiller with Train A out of service for maintenance on October 21, 2020
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Unit 1, Fire Area 16-K, Auxiliary instrument room #1 on October 5, 2020.
- (2) Unit 3, Fire Area 16-A, Control bay chiller room, on October 5, 2020.
- (3) Unit 3, Fire Area 21, Diesel generator building on October 9, 2020.
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (2 Samples)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Units 1 and 2, 4kV Shutdown board room C on October 6, 2020
- (2) Unit 2 Reactor building elevation 565' on November 19, 2020
71111.08G - Inservice Inspection Activities (BWR)
BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding
Activities (IP Section 03.01)
- (1) The inspectors evaluated boiling water reactor non-destructive testing by reviewing the following examinations from October 12 - 16, 2020:
1. Ultrasonic Testing (UT)
a. DRHR-1-2, Pipe to Valve, ASME Class 2 (reviewed) b. N10-1, Safe End to Pipe, ASME Class 1, Manual UT (reviewed)
2. Magnetic Particle Testing (MT)
a. 1-47B455-2268-IA, High Pressure Coolant Injection (HPCI) Welded, ASME Class 2 (reviewed)
3. Penetrant Testing (PT)
a. MS-1-021-181-C0R0, Replacement of 1-FCV-1-169 and associated piping, ASME Class 3 (reviewed)
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) The licensee completed the annual requalification operating examinations required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2), "Requalification Requirements," of the NRC's "Operator's Licenses." During the week of November 30, 2020, the inspector performed an in-office review of the overall pass/fail results of the individual operating examinations and the crew simulator operating examinations in accordance with Inspection Procedure (IP) 71111.11, "Licensed Operator Requalification Program." These results were compared to the thresholds established in Section 3.02, "Requalification Examination Results of IP 71111.11.
The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam completed on September 25, 2020.
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 the following activities:
- Unit 1 shutdown and cooldown activities to support refueling outage 1R13 on October 3, 2020, and October 4, 2020
- Unit 1 startup on November 4, 2020
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator requalification training in the Unit 2 simulator on November 19, 2020.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Unit 2, Function 047-C, Heat removal function of the Turbine Generator Controls EHC system following maintenance to disable main steam bypass valve 1 in the closed position on September 27, 2020.
- (2) Units 1, 2 and 3, Function 055-B, Annunciator system associated with the diesel generators on December 16, 2020.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 1, High risk evolution (HRE) during lowered inventory until the completion of cavity flood-up and fuel pool gates removed from October 4, 2020 to October 6, 2020.
- (2) Unit 1, Yellow shutdown risk due to high decay heat on October 3, 2020.
- (3) Unit 1, Heavy lift of the reactor pressure vessel head lift on October 6, 2020.
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Operability determination of offsite power via Unit Station Service Transformer (USST) 2B after receipt of USST 2B Load Tap Changer Abnormal alarm on October 2, 2020.
- (2) Unit 1 and 2, Shutdown board A battery following discovery of a degraded cell on August 27, 2020.
- (3) Unit 1, Operability evaluation associated with a degraded flow indication for 1B reactor recirculation pump on October 30, 2020.
- (4) Unit 1, Main steam line B relief valve following leakage found at the bolted connection between the pilot base to main body of the valve during reactor coolant system pressure test performed on October 29, 2020.
===71111.17T - Evaluations of Changes, Tests, and Experiments
Sample Selection (IP Section 02.01)
The inspectors evaluated unresolved item (URI)05000260/2020010-01, "Water Hammer Analysis for Unit 2 HPCI Turbine Exhaust Piping," related to engineering change 71988, for closure.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01)===
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Units 1 and 2, Control bay chiller B after replacement of condenser fan motor on October 5, 2020
- (2) Units 1 and 2, C 4kV shutdown board testing following preventative maintenance and a design change on October 17, 2020
- (3) Unit 3, Electric board room air conditioning unit (ACU) 3B post maintenance testing following planned maintenance activities on November 22, 2020
- (4) Unit 2, Reactor core isolation cooling (RCIC) steam line inboard isolation valve breaker following thermal overload heater replacement on December 12, 2020
- (5) Unit 1, 1B recirculation pump flow temporary modification on December 9, 2020
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated Unit 1 refueling outage activities from October 2, 2020 to November 7, 2020.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Unit 1, 1-SR-3.1.7.7, Standby Liquid Control (SLC) System Functional Test on October 20, 2020
- (2) Unit 3, 3-SR-3.5.1.6(CS II), Core Spray Flow Rate Loop II on October 23, 2020
- (4) Unit 1, 0-SR-3.8.1.9(A), Diesel Generator A Emergency Unit 1 Load Acceptance Test on October 8, 2020
- (5) Units 1, 2, and 3, 0-SI-4.5.C.1(C2), C2 Residual Heat Removal Service Water (RHRSW) Quarterly Flowrate Test on November 23, 2020
- (6) Unit 1, 1-SR-3.1.4.1, SCRAM Insertion Times Test on October 3, 2020
- (7) Unit 3, 3-SR-3.5.1.7, HPCI Main and Booster Pump Set Developed Head and Flow Rate Test at Rated Reactor Pressure on December 9, 2020.
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
- (1) Unit 1, Pressure isolation valve leak test of residual heat removal (RHR) low pressure core injection valves, 1-FCV-74-67 and 1-CKV-74-68, on October 16, 2020
FLEX Testing (IP Section 03.02) (1 Sample)
- (1) Testing of Triton FLEX Floating Booster Pump on November 9, 2020
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) Classification and notification during licensed operator requalification simulator training in the Unit 3 Simulator on November 19,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Contamination and Radioactive Material Control (IP Section 03.03) (1 Sample)
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.
- (1) Observed controls for highly radioactive materials stored in the spent fuel pool.
Radiological Hazards Control and Work Coverage (IP Section 03.04) (2 Samples)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.
- (1) Unit 3 Transversing Incore Probe room entry.
- (2) Unit 3 under-vessel maintenance activities.
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (1 Sample)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) Refuel floor area.
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01)
- (1) Inspectors evaluated the licensees performance in controlling, labelling and securing radioactive materials.
Radioactive Waste System Walkdown (IP Section 03.02 (1 Sample)
- (1) Inspectors walked down accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality.
Waste Characterization and Classification (IP Section 03.03) (2 Samples)
The inspectors evaluated the licensees characterization and classification of radioactive waste.
(1)2020 Reactor Water Cleanup Waste (2)2020 Dry Active Waste (DAW)
Shipment Preparation (IP Section 03.04) (1 Sample)
- (1) The inspectors observed that a shipment containing radioactive material was prepared according to requirements.
Shipping Records (IP Section 03.05) (4 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
- (1) RW 19-211, Type B, Filters
- (2) RW 20-096, Type B, Resin
- (3) RW 19-158, Type B, Irradiated Equipment
- (4) RW 20-097, SCO, Contaminated Pump
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===
- (1) Unit 1 (October 1, 2019 - September 30, 2020)
- (2) Unit 2 (October 1, 2019 - September 30, 2020)
- (3) Unit 3 (October 1, 2019 - September 30, 2020)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (3 Samples)
- (1) Unit 1 (October 1, 2019 - September 30, 2020)
- (2) Unit 2 (October 1, 2019 - September 30, 2020)
- (3) Unit 3 (October 1, 2019 - September 30, 2020)
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (3 Samples)
- (1) Unit 1 (October 1, 2019 - September 30, 2020)
- (2) Unit 2 (October 1, 2019 - September 30, 2020)
- (3) Unit 3 (October 1, 2019 - September 30, 2020)
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) March 22, 2019 - October 1, 2020
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in biofouling mitigation and operator performance that might be indicative of a more significant safety issue.
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) The inspectors conducted safety culture interviews with individuals from operations, training, radiation protection, and engineering during and prior to the most recent refueling outage on Unit 1. The inspectors concluded that employees interviewed were willing to raise nuclear safety concerns through at least one of the several means available without fear of retaliation.
- (2) Condition Report (CR) 1624488, Marine biofouling that resulted in damage to the plant's traveling water screens, Unit 1 and 2 Shutdown, and Unit 3 reduction in power
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 05000259/2020-001-00, Manual Reactor Shutdown of Two Units on Decreasing Condenser Vacuum due to Eel Grass Intrusion (ADAMS Accession No.
ML20260H103), 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 inspectors did not identify a violation of NRC requirements.
- (2) LER 05000259/2020-001-01, Manual Reactor Shutdown of Two Units on Decreasing Condenser Vacuum due to Eel Grass Intrusion (ADAMS Accession No.
ML20322A440), 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 inspectors did not identify a violation of NRC requirements. The inspectors reviewed the updated LER submittal.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants Operation of an Independent Spent Fuel Storage Installation at Operating Plants
- (1) The inspectors evaluated the licensees activities related to long-term operation and monitoring of their independent spent fuel storage installation.
INSPECTION RESULTS
URI Water Hammer Analysis for Unit 2 HPCI Turbine Exhaust Piping URI 05000260/2020010-01 71111.17T
Description:
The NRC opened an unresolved item in inspection report 05000259/2020010, 05000260/2020010 and 05000296/2020010 (ADAMS Accession Number ML20174A300) in order to determine if a violation of 10 CFR 50.59 existed pertaining to the effects of water hammer on the Unit 2 high pressure coolant injection (HPCI) turbine exhaust piping. Engineering Change (EC) 71988 implemented a modification to the Unit 2 HPCI turbine exhaust line and HPCI vacuum breaker subsystem to minimize backflow from the suppression pool into the HPCI exhaust line following a HPCI turbine trip. The Browns Ferry Updated Final Safety Analysis Report (UFSAR) Section 6.4.1 stated that the function of the vacuum breakers was to prevent intermittent negative pressure in the exhaust piping from pulling water out of the torus and causing a water hammer problem. The UFSAR also stated that the HPCI system piping material is composed of carbon steel and is designed to USA Standard (USAS) B31.1.0-1967, Power Piping, which required in section 101.5, Dynamic Effects, that impact forces caused by all external and internal conditions (e.g., water hammer)be considered in the piping design.
Calculation MDQ0020732016000535, "Analysis of Browns Ferry Nuclear Unit 2 HPCI Turbine Exhaust Steam Line Transient Loads Following HPCI Turbine Exhaust System Plant Modifications," Revision 1, analyzed the effects of water hammer induced piping loads in the exhaust lines following the plant modifications to ensure the exhaust lines could handle the stresses upon restarting. The inspectors identified that MPR Report 0048-0052-RPT-001, "Independent Technical Review on Browns Ferry Unit 2 HPCI Turbine Exhaust Piping Proposed Modification," Revision 1, stated that the calculation used a non-conservative assumption of 2% water volume as an input into the water hammer analysis in calculation CDQ0020732016000533, "Browns Ferry Nuclear Plant Summary of Piping Analysis N1-273-01R," Revision 4. The inspectors questioned if the stresses in the HPCI turbine exhaust piping remained within the limits set forth in USAS B31.1.0-1967 upon restarting of the HPCI pump.
To address the issue, the licensee developed a new model of the HPCI turbine exhaust line in calculation MDQ0000732020001009, "Analysis of HPCI Turbine Exhaust Steam Line Transient Loads," Revision 0, to reflect the appropriate water volume in the exhaust line and revised calculation CDQ0020732016000533 to evaluate the impact of the stresses caused on the piping upon HPCI restarting. The licensee concluded that, based on the evaluations performed, the stresses caused by a HPCI restart on the turbine exhaust piping would not result in exceeding the allowable stress limits set forth in USAS B31.1.0-1967. The inspectors reviewed the licensee's evaluation and did not identify a violation of 10 CFR 50.59 requirements.
Corrective Action Reference(s): Condition Report 1606616
Enforcement Discretion Enforcement Action EA-20-135: Failure to Comply with 10 CFR 37 for the Protection of Disused Steam Dryer Pieces Stored in a Concrete Module 71124.08
Description:
From April 29, 2018 - April 20, 2019 the licensee moved pieces of activated/contaminated steam dryers into a large concrete storage module outside the Protected Area. Although this waste material exceeded the threshold for a Category 2 quantity of radioactivity, it did not contain discrete radioactive sources, ion-exchange resins, or activated material that weighs less than 2,000 kg. Therefore, the steam dryer waste is exempt from 10 CFR 37 Subparts B, C, and D, but must comply with the requirements of 10 CFR 37.11(c)(1) - 10 CFR 37.11(c)(4) instead. The inspectors noted that there was no monitored alarm system at the access points to the concrete module.
Corrective Actions: The licensee entered the issue into their corrective action program.
Corrective Action References: CR 1646655
Enforcement:
Violation: 10 CFR 37.11(c)(2) requires that a Category 2 quantity of radioactive waste, that is exempt from Subparts B, C, and D, must be secured with a monitored alarm at the access control point. Contrary to this, from April 29, 2018 to the present, the licensee has stored a Category 2 quantity of exempt waste in a concrete storage module with no monitored alarm system at the access control point.
Basis for Discretion: This violation met the criteria for Enforcement Discretion as described in Enforcement Guidance Memorandum (EGM) 14-001, "Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52." For tracking purposes, this Enforcement Discretion is being documented as a Minor violation with associated Enforcement Action number EA-20-135.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 26, 2021, the inspectors presented the integrated inspection results to Mr.
Matthew Rasmussen, Site Vice President and other members of the licensee staff.
- On October 16, 2020, the inspectors presented the ISI Exit Meeting inspection results to S.M. Bono, Site Vice President and other members of the licensee staff.
- On October 23, 2020, the inspectors presented the RP Inspection Exit Meeting inspection results to Barry Tidwell, Technical Assistant to the Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
60855.1
Procedures
0-SR-DCS3.1.2.1
Spent Fuel Storage Inspection
Revision
25
Procedures
0-AOI-100-3
Flood Above Elevation 558'
Revision
0048
0-AOI-100-7
Severe Weather
Revision 46
0-TI-599
External Flood Protection Program
Revision
0002
0-TI-600
External Flood Protection Program Bases Document
Revision
0003
NPG-SPP-07.1.8
Severe Weather and Natural Disasters
Revision 1
NPG-SPP-09.22
External Flood Protection Program
Revision
0003
Drawings
3-47E866-7
Flow Diagram Air Conditioning Chilled Water
Procedures
0-OI-31
Control Bay and Off-Gas Treatment Building Air
Conditioning System
163
0-OI-31-ATT-1
Valve Lineup Checklist
137
Drawings
0-47E864-4
Flow Diagram Ventilation & Air Conditioning Air Flow
Revision 67
Fire Plans
FPR-Volume 2
Fire Protection Report Volume 2
Revision 67
Calculations
NDN-000-999-2007-
0031
BFN Probabilistic Risk Assessment - Internal Flooding
Analysis
Revision
2
NDN00099920070031
BFN Probabilistic Risk Assessment - Internal Flooding
Analysis
Revision 2
Corrective Action
Documents
CR 1478387, 1440533,
1446447, 1444522,
13390711, 1346921,
1575085, 1471958,
1617180, 1625454,
25455, 1650049
CRs 1640334, 1640153,
26190, 1626176,
1610483, 1647115,
1455874
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
System 055 Health Report
U1/2 Function/System 055-B (a)(1) Plan
Revision 1
20-EEB-047-238
Lift Servo Wires to Disable U2 BPV #1 in the Closed
Position
09/27/2020
Procedures
0-TI-346
Maintenance Rule Performance Indicator Monitoring,
Trending, and Reporting - 10CFR50.65
0-TI-346
Maintenance Rule Performance Indicator Monitoring,
Trending, and Reporting - 10CFR50.65
Revision 53
Work Orders
119871580, 119871577,
119871578, 119871579,
21726332, 121142067,
21643646, 121276680,
119822353
WOs 119946024,
21618778, 121619276
Engineering
Evaluations
EWR20MEB072099
BFN Unit 1 Core Decay Heat Load Analysis
07/17/20
Miscellaneous
Unit 1 Cycle R13 - Outage Safety Plan
Procedures
0-TPP-FPP-011
BFN NFPA 805 Non-Power Operations Fire Risk
Management
Revision 4
MSI-0-000-LFT001
Lifting Instructions for the Control of Heavy Loads
Revision 77
NPG-SPP-10.6
Infrequently Performed Test or Evolution
Revision 2
Calculations
EDQ02482003002
4160V Shutdown Boards A, B, C, D, and 3EB 250V
DC Battery Load Study, Voltage Drop, and Short
Circuit Calculation
Revision 19
Corrective Action
Documents
CR 1632677
CR 1641624
CRs 1648565, 1648452,
1648258
Drawings
1-47E610-68-1
Mechanical Control Diagram Reactor Recirculation
System
Revision 23
7567F-000
Model 7567F 6x10 Relief Valve
Miscellaneous
Adverse Condition Monitoring and Contingency Plan
11/02/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
for 1-FE-68-81
Operational Decision-Making Issue Evaluation
Document for CR 1649288
11/02/2020
Operability
Evaluations
Prompt Determination of Operability Documentation
for CR 1649288
Procedures
OPDP-11
Operational Decision-Making Issue Evaluation
Process
Revision 9
OPDP-8
Operability Determinations Process and Limiting
Conditions for Operation Tracking
Revision 26
Work Orders
WOs 121703225,
21702130, 121690633,
20590185
71111.17T Calculations
CDQ0020732016000533
Browns Ferry Nuclear Plant Summary of Piping
Analysis N1-273-01R
Revision 5
MDQ0000732020001009 Analysis of HPCI Turbine Exhaust Steam Line
Transient Loads
Revision 0
MDQ0020732016000535 Analysis of Browns Ferry Nuclear Unit 2 HPCI Turbine
Exhaust Steam Line Transient Loads Following HPCI
Turbine Exhaust System Plant Modifications
Revision 1
Miscellaneous
BFN-50-C-7103
Structural Analysis and Qualification of Mechanical
and Electrical Systems (Piping and Instrument Tubing)
Revision 7
Corrective Action
Documents
CR 1490500, 1652321,
1652433, 1653660
CR 1656181
Drawings
0-45E765-3
Wiring Diagram 4160V Shutdown Aux Power
Schematic Diagram
Revision 39
0-731E761-11
Elementary Diagram Emergency Equipment
Revision 25
0-76N4D-2
Wiring Diagram A/C Unit
Revision 7
2-45E2750-1
Wiring Diagram 480V Reactor MOV Board 2B
Connection Diagram
Revision 11
2-45E779-12
Wiring Diagram 480V Shutdown Aux Power Schematic
Diagram
Revision 21
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
3-45E3750-7
Wiring Diagram 480V Reactor MOV Board 3B
Connection Diagram
Revision 9
3-76N3S-1
Mechanical P.I.D. Piping Schematic EBR ACU 3A
Revision 1
Engineering
Changes
BFN-19-346-10
Rewire Breaker 1624 Critical STA Functions from the
STA Switch to the Breaker Auxiliary Contacts
Revision 2
Miscellaneous
BFN-VTD-E322-0220
Ellis and Watts - (C360 Air Conditioner) Installation,
Operation, Maintenance Manual
Revision 2
Procedures
1/2-ETU-SMI 3-C.4
Relay Calibration on 4kV Shutdown Board C
Revision 13
ECI-0-000-BKR008
Testing and Troubleshooting of Molded Case Circuit
Breakers and Motor Starter Overload Relays
Revision
109
EPI-0-000-BKR015
4kV Wyle/Siemens Horizontal Vacuum Circuit Breaker
(Type-3AF) and Compartment Maintenance
Revision 45
EPI-0-000-SWG001
Maintenance of 4160V GE Switchgear/Board Busses
and Compartments
Revision 27
EPI-3-031-CHR001
The Inspection and Maintenance of the Electric Board
Room 3A/3B Air Conditioning Unit
Revision 41
NPG-SPP-07.1.4
Work Management Prioritization-On Line
Revision 16
Work Orders
118744454, 120861091,
20160001,
21746995,120680730,
21738807, 121745488
20308063, 120593773,
20308064, 121297555,
21297562, 120593810,
20593799, 120251778
21767501
Corrective Action
Documents
CR 1648979
CR 1650962, 1651270
Drawings
1-47E811-1-APPJ
Appendix J Testing Boundary for Residual Heat
Removal System
Revision 8
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
1-47E858-1
Flow Diagram RHR Service Water System
Revision 72
2-47E858-1
Flow Diagram RHR Service Water System
Revision 30
Procedures
0-SR-3.8.1.9(A)
Diesel Generator A Emergency Unit 1 Load
Acceptance Test
Revision
0013
0-SR-4.5.C.1(C2)
RHRSW Pump C2 IST Group A Quarterly Pump Test
Revision 12
0-TI-360
Containment Leak Rate Programs
Revision 48
1-SI-3.2.74(RHR II)
Pressure Isolation Valve Leakage Test RHR Loop II
Shutdown Cooling Return
Revision 11
1-SR-3.1.4.1
SCRAM Insertion Times
Revision
0018
1-SR-3.1.7.7
Standby Liquid Control System Functional Test
1-SR-3.5.1.9 (RHR II)
Loop II RHR Simulated Automatic Actuation Test
Revision
0017
3-SR-3.5.1.6(CS II)
Core Spray Flow Rate Loop II
FMS-FLEX Pump
Fleet Maintenance Strategy FLEX-Pump-T3 NET
Diesel Driven
Revision 1
PM Job Plan 79413
Triton Satellite Pump Maintenance and Diesel Engine
Run
Revision 1
Work Orders
1-SR-3.5.1.9(RHR II) - Loop II RHR Simulated
Automatic Actuation Test
10/04/2020
0-SR-3.8.1.9(A) - Diesel Generator 'A' Emergency Unit
Load Acceptance Test
10/10/2020
3-SR-3.5.1.7 - HPCI Main and Booster PMP Set
Developed Head & Flow Rate Test at Rated Rx
Pressure
2/10/2020
1-SR-3.1.4.1 - SCRAM Insertion Times
10/05/2020
Corrective Action
Documents
CR 1545278
Corrective Action
Documents
Resulting from
CR 1646655
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Inspection
Engineering
Evaluations
Low Level Waste Storage Module Number 1 -
Inventory
Procedures
Radioactive Material Shipping Manual, Volumes I - III
Corrective Action
Documents
CRs 1543185, 1547045,
1560358, 1563233,
1569243, 1617191,
1617669, 1633311,
1650303, 1635949,
1635050, 1633311,
1639000, 1547045,
1560358
Self-
Assessments
Site Trimester Performance Assessment, BFN, June
20-September 2020