IR 05000259/2020006
| ML21062A266 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/03/2021 |
| From: | Mark Miller Division Reactor Projects II |
| To: | Jim Barstow Tennessee Valley Authority |
| References | |
| IR 2020006 | |
| Download: ML21062A266 (7) | |
Text
March 3, 2021
SUBJECT:
ANNUAL ASSESSMENT LETTER FOR BROWNS FERRY NUCLEAR PLANT,
UNITS 1, 2 AND 3 - REPORT 05000259/2020006, 05000260/2020006 AND
Dear Mr. Barstow:
The NRC has completed its end-of-cycle performance assessment of Browns Ferry Nuclear Plant, Units 1, 2, and 3, reviewing performance indicators (PIs), inspection results, and enforcement actions from January 1, 2020 through December 31, 2020. This letter informs you of the NRCs assessment of your facility during this period and its plans for future inspections at your facility. The NRC concluded that overall performance at your facility was consistent with ensuring public health and safety. The baseline inspection program was completed at your facility as defined in Inspection Manual Chapter 2515, Light-Water Reactor Inspection Program
- Operations Phase.
The NRC determined the performance at Browns Ferry Nuclear Plant, Units 1, 2, and 3 during the most recent quarter was within the Licensee Response Column (Column 1), the highest performance category of the NRCs Reactor Oversight Process (ROP) Action Matrix, because all inspection findings had very low safety significance (i.e., Green), and all PIs were within the expected range (i.e., Green). Therefore, the NRC plans to conduct ROP baseline inspections at your facility.
Browns Ferry Nuclear Plant, Units 1, 2 and 3 were in the NRC Regulatory Response Column (Column 2) for the first three quarters of calendar year (CY) 2020 for the greater-than-Green inspection finding in the Security cornerstone identified in the fourth quarter of CY 2019. On September 4, 2020, the NRC completed a review of your corrective actions for the greater-than-Green inspection finding in the Security cornerstone, using Inspection Procedure 95001,
"Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area." The NRC's inspection was documented in NRC inspection report Nos. 05000259, 260, and 296/2020440, which is publicly available in ADAMS Accession No. ML20262H105. Based on the results of this inspection, the NRC determined the performance at Browns Ferry Nuclear Plant, Units 1, 2 and 3 returned to the Licensee Response Column (Column 1) of the ROP in the fourth quarter of CY 2020.
The enclosed inspection plan lists the inspections scheduled through December 31, 2022.
The NRC is providing the inspection plan to allow for the resolution of any scheduling conflicts and personnel availability issues. Routine inspections performed by resident inspectors are not included in the inspection plan. The inspections listed during the last twelve months of the inspection plan are tentative and may be revised. The NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes. In response to the COVID-19 public health emergency (PHE), the NRC is adjusting inspection plans and schedules in order to safeguard the health and safety of both NRC and your staffs while still effectively implementing the ROP. Each planned inspection is being carefully reviewed in order to determine if any portions of the inspection can be performed remotely, how best to perform on-site portions to minimize personnel health risks and adjust inspection schedules if needed. This is done in accordance with guidance contained in the February 1, 2021 memo, Calendar Year 2021 Inspection Guidance During COVID-19 Telework Restrictions (ADAMS Accession No. ML21027A274). For inspections requiring extensive coordination with offsite organizations, such as evaluated emergency preparedness exercises, NRC guidance and frequently asked questions for security and emergency preparedness can be found here: https://www.nrc.gov/about-nrc/covid-19/security-ep/. Similarly, the NRC has developed guidance if force-on-force inspections cannot be completed as scheduled due to an emergency, such as the COVID-19 PHE. These changes help ensure the health and safety of both NRC and licensee staff while maintaining the NRCs important safety and security mission during the COVID-19 PHE. The attached inspection plan is accurate on the date of issuance but remains subject to change based on approval of potential exemption requests or other changes needed due to changing conditions during the COVID-19 PHE. NRC staff will contact your appropriate regulatory affairs staff in order to coordinate inspection planning and scheduling.
In addition to the ROP baseline inspections, we also plan on conducting infrequently performed inspections which include two Initial License Examinations and Temporary Instruction 2515/193, Inspection of The Implementation of EA13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions in 2021.
Based on investigations completed in late 2019 and early 2020 involving two allegations of discrimination, the NRC issued TVA a Notice of Violation (NOV) on August 24, 2020. The NOV citied three Severity Level (SL) II and one SL I violation, and proposed imposition of a $606,942 Civil Penalty (CP) (ADAMS Accession Number ML20218A483). TVA responded to the NOV in a letter dated September 23, 2020 and denied all four violations (ADAMS Accession Number ML20274A014). Subsequently, the NRC issued an order imposing the CP to TVA on October 29, 2020 (ADAMS Accession Number ML20297A525). On November 30, 2020, TVA requested a hearing on the substantiated cases of discrimination; that hearing will occur later in calendar year 2021. Therefore, the NRC will defer scheduling inspection procedure 92722, Follow up Inspection for Any Severity Level I or II Traditional Enforcement Violation or for Two or More Severity Level III Traditional Enforcement Violations in a 12 Month Period, until the matter is settled. During end-of-cycle assessment meetings that follow issuance of escalated enforcement discrimination violations, the NRC is required to evaluate whether a theme exists in the safety conscious work environment (SCWE) cross-cutting area that could necessitate corrective actions by the licensee and greater oversight by the NRC. Inspection Manual Chapter 0305, Operating Reactor Assessment Program, states that a cross-cutting theme in the area of SCWE exists if the licensee has received correspondence from the NRC that transmitted (1) a SL I, II, or III enforcement action that involved discrimination or (2) a confirmatory order that involved discrimination. Although the NRCs process suggests that a SCWE theme exists due to the enforcement actions issued on August 24, 2020, we note that the incidents leading to the proposed enforcement actions are not indicative of current performance at Browns Ferry in this area. The NRC has conducted multiple safety culture inspections at each TVA site since 2018 and has determined that TVA has made sufficient progress in addressing SCWE concerns and has demonstrated an improving safety culture since 2018.
In addition, the NRC recently issued a NOV with SL III and Exercise of Enforcement Discretion (No CP) on January 21, 2021, related to a security finding at Browns Ferry (ADAMS Accession No. ML21021A369). Therefore, the NRC plans to conduct a follow-up inspection procedure 92702, Follow-up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, and Orders, of this NOV in August 2021.
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, and Requests for Withholding.
Please contact Thomas Stephen at (404) 997-4703 with any questions you may have regarding this letter.
Sincerely,
/RA/
Mark S. Miller, Director Division of Reactor Projects
Docket Nos.: 50-259, 50-260, 50-296 License Nos.: DPR-33, DPR-52, DPR-68
Enclosure:
Browns Ferry Inspection/Activity Plan (01/01/2021-12/31/2022)
cc Distribution via ListServ
OFFICE RII/DRP RII/DRP RII/DRP RII/DRP NAME S. Ninh J. Steward T. Stephen M. Miller DATE 3/02/2021 3/01/2021 3/02/2021 3/03/2021
Browns Ferry 03/01/2021 - 12/31/2022 Unit Start End Activity CAC Title Staff Count UNIT 2 IN-SERVICE INSPECTION
2 03/01/2021 03/05/2021 IP 71111.08G 000701 Inservice Inspection Activities (BWR)
RP OCCUPATIONAL RAD SAFETY BASELINE INSPECTION
1, 2, 3 03/08/2021 03/12/2021 IP 71124.01 000725 Radiological Hazard Assessment and Exposure Controls 1, 2, 3 03/08/2021 03/12/2021 IP 71124.02 000726 Occupational ALARA Planning and Controls 1, 2, 3 03/08/2021 03/12/2021 IP 71124.03 000727 In-Plant Airborne Radioactivity Control and Mitigation 1, 2, 3 03/08/2021 03/12/2021 IP 71124.04 000728 Occupational Dose Assessment 1, 2, 3 03/08/2021 03/12/2021 IP 71124.05 000729 Radiation Monitoring Instrumentation 1, 2, 3 03/08/2021 03/12/2021 IP 71151 000746 Performance Indicator Verification 1, 2, 3 04/12/2021 04/16/2021 IP 71124.01 000725 Radiological Hazard Assessment and Exposure Controls 1, 2, 3 04/12/2021 04/16/2021 IP 71124.02 000726 Occupational ALARA Planning and Controls 1, 2, 3 04/12/2021 04/16/2021 IP 71124.03 000727 In-Plant Airborne Radioactivity Control and Mitigation 1, 2, 3 04/12/2021 04/16/2021 IP 71124.04 000728 Occupational Dose Assessment 1, 2, 3 04/12/2021 04/16/2021 IP 71124.05 000729 Radiation Monitoring Instrumentation 1, 2, 3 04/12/2021 04/16/2021 IP 71151 000746 Performance Indicator Verification BROWNS FERRY INITIAL LICENSE EXAM
1, 2, 3 04/12/2021 04/16/2021 OV 000956 VALIDATION OF INITIAL LICENSE EXAMINATION (OV)
1, 2, 3 05/17/2021 05/28/2021 EXAD 000500 LICENSE EXAM ADMINISTRATION (EXAD)
SECURITY BASELINE INSPECTION
1, 2, 3 04/19/2021 04/23/2021 IP 71130.04 000736 Equipment Performance, Testing, and Maintenance 1, 2, 3 04/19/2021 04/23/2021 IP 71130.07 000739 Security Training 1, 2, 3 04/19/2021 04/23/2021 IP 92702 001436 Follow-Up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, and Orders DESIGN BASES ASSURANCE INSPECTION (TEAMS)
1, 2, 3 05/17/2021 05/21/2021 IP 71111.21M 000713 Design Bases Assurance Inspection (Teams)
1, 2, 3 06/07/2021 06/11/2021 IP 71111.21M 000713 Design Bases Assurance Inspection (Teams)
RP PUBLIC RAD SAFETY INSPECTION
1, 2, 3 06/07/2021 06/11/2021 IP 71124.06 000730 Radioactive Gaseous and Liquid Effluent Treatment 1, 2, 3 06/07/2021 06/11/2021 IP 71124.07 000731 Radiological Environmental Monitoring Program 1, 2, 3 06/07/2021 06/11/2021 IP 71151 000746 Performance Indicator Verification Page 1 of 3 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
IP 22 Inspection Activity Plan Report
Browns Ferry 03/01/2021 - 12/31/2022 Unit Start End Activity CAC Title Staff Count EMERGENCY PREPAREDNESS EXERCISE
1, 2, 3 06/21/2021 06/25/2021 IP 71114.01 000716 Exercise Evaluation 1, 2, 3 06/21/2021 06/25/2021 IP 71151 001397 Performance Indicator Verification SECURITY BASELINE INSPECTION
1, 2, 3 07/19/2021 07/23/2021 IP 71130.02 000734 Access Control 1, 2, 3 07/19/2021 07/23/2021 IP 71130.05 000737 Protective Strategy Evaluation 1, 2, 3 07/19/2021 07/23/2021 IP 71130.09 001656 Security Plan Changes 1, 2, 3 07/19/2021 07/23/2021 IP 71151 001338 Performance Indicator Verification RELIABLE HARDENED CONTAINMENT VENT TI-193
1, 2, 3 08/02/2021 08/05/2021 TI 2515/193 000511 Inspection of the Implementation of EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions TARGET SET INSPECTION
1, 2, 3 12/06/2021 12/10/2021 IP 71130.14 000743 Review of Power Reactor Target Sets NFPA 805 TRIENNIAL FIRE PROTECTION INSPECTION
1, 2, 3 01/31/2022 02/04/2022 IP 71111.21N.05 001646 Fire Protection Team Inspection (FPTI)
1, 2, 3 02/14/2022 02/18/2022 IP 71111.21N.05 001646 Fire Protection Team Inspection (FPTI)
UNIT 3 IN-SERVICE INSPECTION
3 02/28/2022 03/04/2022 IP 71111.08G 000701 Inservice Inspection Activities (BWR)
RP OCCUPATIONAL RAD SAFETY BASELINE AND TRANSPORTATION INSPECTION
1, 2, 3 02/28/2022 03/04/2022 IP 71124.01 000725 Radiological Hazard Assessment and Exposure Controls 1, 2, 3 02/28/2022 03/04/2022 IP 71124.08 000732 Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation 1, 2, 3 02/28/2022 03/04/2022 IP 71151 000746 Performance Indicator Verification FORCE-ON-FORCE PLANNING AND EXERCISE WEEKS
1, 2, 3 05/16/2022 05/20/2022 IP 71130.03 000735 Contingency Response - Force-On-Force Testing 1, 2, 3 06/06/2022 06/10/2022 IP 71130.03 000735 Contingency Response - Force-On-Force Testing BROWNS FERRY INITIAL LICENSE EXAM
1, 2, 3 05/16/2022 05/20/2022 OV 000956 VALIDATION OF INITIAL LICENSE EXAMINATION (OV)
Page 2 of 3 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
IP 22 Inspection Activity Plan Report
Browns Ferry 03/01/2021 - 12/31/2022 Unit Start End Activity CAC Title Staff Count BROWNS FERRY INITIAL LICENSE EXAM
1, 2, 3 06/20/2022 06/24/2022 EXAD 000500 LICENSE EXAM ADMINISTRATION (EXAD)
EMERGENCY PREPAREDNESS PROGRAM INSPECTION
1, 2, 3 06/20/2022 06/24/2022 IP 71114.02 000717 Alert and Notification System Testing 1, 2, 3 06/20/2022 06/24/2022 IP 71114.03 000718 Emergency Response Organization Staffing and Augmentation System 1, 2, 3 06/20/2022 06/24/2022 IP 71114.05 000720 Maintenance of Emergency Preparedness 1, 2, 3 06/20/2022 06/24/2022 IP 71151 001397 Performance Indicator Verification DESIGN BASES ASSURANCE INSPECTION (PROGRAMS)
1, 2, 3 07/18/2022 07/22/2022 IP 71111.21N.02 001645 Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements 1, 2, 3 08/01/2022 08/05/2022 IP 71111.21N.02 001645 Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements PROBLEM IDENTIFICATION AND RESOLUTION
1, 2, 3 08/08/2022 08/12/2022 IP 71152B 000747 Problem Identification and Resolution 1, 2, 3 08/22/2022 08/26/2022 IP 71152B 000747 Problem Identification and Resolution SECURITY BASELINE INSPECTION
1, 2, 3 08/15/2022 08/19/2022 IP 71130.02 000734 Access Control 1, 2, 3 08/15/2022 08/19/2022 IP 71130.04 000736 Equipment Performance, Testing, and Maintenance 1, 2, 3 08/15/2022 08/19/2022 IP 71130.07 000739 Security Training 1, 2, 3 08/15/2022 08/19/2022 IP 71130.09 001656 Security Plan Changes 1, 2, 3 08/15/2022 08/19/2022 IP 71151 001338 Performance Indicator Verification BROWNS FERRY REQUAL INSPECTION
1, 2, 3 09/12/2022 09/16/2022 IP 71111.11B 000704 Licensed Operator Requalification Program and Licensed Operator Performance UNIT 1 IN-SERVICE INSPECTION
1 10/03/2022 10/07/2022 IP 71111.08G 000701 Inservice Inspection Activities (BWR)
Page 3 of 3 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
IP 22 Inspection Activity Plan Report