IR 05000259/2020011

Biennial Problem Identification and Resolution Inspection Report 05000259/2020011, 05000260/2020011 and 05000296/2020011

ML20302A003
Person / Time
Site:	Browns Ferry
Issue date:	10/26/2020
From:	Tom Stephen NRC/RGN-II/DRP/RPB5
To:	Jim Barstow Tennessee Valley Authority
References
IR 2020011
Download: ML20302A003 (14)

Text

October 26, 2020

SUBJECT:

BROWNS FERRY NUCLEAR PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000259/2020011, 05000260/2020011 AND 05000296/2020011

Dear Mr. Barstow:

On September 18, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Browns Ferry Nuclear Plant. On September 17, 2020 the NRC inspectors discussed the results of this inspection with Mr. Steven M. Bono and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.

Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

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 and 05000296 License Nos. DPR-33, 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:

05000259/2020011, 05000260/2020011 and 05000296/2020011

Licensee:

Tennessee Valley Authority

Facility:

Browns Ferry Nuclear Plant

Location:

Athens, Alabama

Inspection Dates:

August 24, 2020 to September 18, 2020

Inspectors:

J. Hamman, Reactor Inspector (Team Lead)

M. Kennard, Sr. Operations Engineer

S. Ninh, Senior Project Engineer

R. Rodriguez, Senior Project Engineer

J. Seat, Senior 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 a biennial problem identification and resolution 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

None.

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 (COVID-19),inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or portion 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.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

(1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.

• Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of equipment aging issues.

• Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits, and self-assessments.

• Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B Based on the samples reviewed, the team determined that the licensees corrective action program (CAP) complied with regulatory requirements and self-imposed standards. The licensees implementation of the corrective action program adequately supported nuclear safety.

Problem Identification: The inspectors determined that the licensee was effective in identifying problems and entering them into the corrective action program and there was a low threshold for entering issues into the corrective action program. This conclusion was based on a review of the requirements for initiating Condition Reports (CRs) as described in licensee procedure NPG-SPP-22.300, Corrective Action Program, and managements expectation that employees were encouraged to initiate condition reports for any reason. Additionally, site management was actively involved in the corrective action program and focused appropriate attention on significant plant issues. Based on reviews and walkdowns of accessible portions of selected systems, the inspectors determined that deficiencies were being identified and placed in the CAP.

Problem Prioritization and Evaluation: Based on the review of CRs sampled by the inspection team during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the CR significance determination guidance in procedure NPG-SPP-22.300. The inspectors determined that in general, adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that plant personnel had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures and cause determinations were appropriate, and considered the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used to evaluate CRs depending on the type and complexity of the issue consistent with the applicable cause evaluation procedures.

Corrective Actions: Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence. The team reviewed performance indicators, CRs, and effectiveness reviews, as applicable, to verify that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence (CAPRs)were sufficient to ensure corrective actions were properly implemented and were effective.

Assessment 71152B Based on the samples reviewed, the team determined that the stations processes for the use of industry and NRC operating experience information and for the performance of audits and self-assessments were effective and complied with all regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. Overall, the team concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented to address lessons learned as needed. In general, the inspectors determined that the licensee was effective at performing self-assessments and audits to identify issues at a low level, properly evaluated those issues, and resolved them commensurate with their safety significance.

Assessment 71152B Based on a sample size of 12 people interviewed from a cross-section of plant employees, as well as a review of condition reports and safety culture survey review, the team found no evidence of challenges to a safety-conscious work environment. Employees interviewed appeared willing to raise nuclear safety concerns through at least one of several means available.

The team reviewed the 2020 Browns Ferry Nuclear Plant Employee Concerns Program Feedback Survey results. Of 342 respondents, 89% responded that they felt free to contact the Employee Concerns Program and 82% responded that they would report an issue or concern to the TVA Ethics or Employee Concerns Program if necessary.

Minor Violation 71152B Minor Violation: 10CFR26.205(d)(3)(iii) states in part that (iii) Individuals who are working 12-hour shift schedules while performing the duties described in § 26.4(a)(1) through (a)(3) shall have at least 2.5 days off per week, averaged over the shift cycle. Contrary to this requirement, during the Spring 2019 outage one Licensed Unit Operator was found to have less than 2.5 days off per week. This was due to the individual incorrectly being placed on an "outage schedule" instead of an "online schedule". An outage schedule permits only one day off per week averaged over the shift cycle.

Screening: The inspectors determined the performance deficiency was minor. This performance deficiency was screened in accordance with Inspection Manual Chapter (IMC)0612 Appendix B, "Additional Screening Guidance," dated January 1, 2020, and was determined to be of minor significance because the failure to meet work hour requirements could not be reasonable viewed as a precursor to a significant event, would not have the potential to lead to a more significant safety concern if left uncorrected, and did not adversely affect a cornerstone objective. Specifically, this violation was a result of a unique staffing challenge during one outage and did not result in any adverse impact to the operation of the Browns Ferry Nuclear Plant.

Enforcement:

The licensee has taken actions to restore compliance under Condition Report 1638399. This failure to comply with 10CFR26 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

• On September 17, 2020, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Steven M. Bono and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71152B

Corrective Action

Documents

1338027, 1420413,

1439517, 1440055,

1446361, 1446381,

1446490, 1448155,

1448229, 1448706,

1449483, 1454252,

1458296, 1458428,

1459513, 1459887,

1461321, 1461612,

1464279, 1469920,

1470821, 1472978,

1475622, 1478349,

1478565, 1480744,

1480847, 1483014,

1485497, 1485501,

1488324, 1490266,

1491888, 1493698,

1494483, 1496991,

1496992, 1499735,

1501541, 1502592,

1510057, 1513132,

22304, 1523272,

25480, 1526205,

26597, 1526999,

1532860, 1535076,

1535806, 1536539,

1537101, 1539981,

1542143, 1545577,

1551628, 1554636,

1555154, 1561790,

1562911, 1565122,

1565969, 1567701,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

1572797, 1575519,

1597225, 1603709,

1604736, 1606732,

1613461, 1619684,

1606581, 1597091,

1586526, 1586521,

1586511, 1584709,

1580336, 1570379,

1553492, 1552023,

1548927, 1548094,

1546756, 1541244,

1541037, 1532170,

21190, 1520850,

1518645, 1517630,

1517627, 1517625,

1511614, 1508356,

1499298, 1491946,

1491941, 1491940,

1486322, 1485219,

1478017, 1477311,

1475055, 1474520,

1467336, 1467325,

1464305, 1464303,

1460752, 1454001,

1453491, 1453164,

1452748, 1450856,

1450520, 1449225,

1438388, 1438384,

1438382, 1437895,

1434563, 1429497,

27962, 1423322,

1416743, 1410577,

1394604, 1383682,

1363100, 1354129,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

1352550, 1334534,

294336, 1286467,

252419, 1213567,

1157981, 1140454,

1139620, 1103676,

1094953, 1085977,

2223, 949751,

2409, 921980,

20424, 920418,

890649, 796578,

791685, 727710,

20569, 681667,

573054, 449110,

25949

27051, 1435845,

1436563, 1437476,

1443388, 1497448,

1501007,1511320,

1511475, 1511484,

1512662, 1513320,

23121, 1538409,

1544529, 1545860,

1552023, 1563633,

1582926, 1587546,

1603161, 1613626,

1942600

Corrective Action

Documents

Resulting from

Inspection

1633570

Quality Assurance (QA) Recommendation Condition

Report Resolution Gap Identified

08/27/2020

1634833

Corrective Action Program (CAP) Related Issues

Identified During Problem Identification and Resolution

Documentation Retrieval

09/20/2020

1637714

Problem Identification and Resolution Fatigue Rule

Issue of Concern

09/15/2020

1637750

NRC identified: 3A SLC pump pistons leaking less than

09/16/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

dpm

1638399

20 BFN NRC Problem Identification and Resolution

Inspection Minor Violation (MV) - 10 CFR 26.205

09/17/2020

1638400

20 BFN Problem Identification and Resolution

Observation - Clearance Related CRs

09/17/2020

1638401

20 BFN NRC Problem Identification and Resolution

Observation - CAP Feedback

09/17/2020

Engineering

Evaluations

0-XFA-031-CHCB XFMR Missing Bolts Access Panel

BFN Civil Design Evaluation

03/01/2019

ABB Case 20190301-

951296

ABB Tech Support for Medium Voltage Dry Transformer

03/01/2019

Miscellaneous

FSAR - 3.8 Standby Liquid Control System

TS Units 1, 2, and 3, 3.1 Reactivity Control Systems

General Design Document - BFN - 50-7063-Standby

Liquid Control System

Browns Ferry Nuclear Plant Employee Concerns

Program Feedback Survey

August 2020

E-mail, Jason Eggart (TVA) to Jeff Hamman (NRC)

providing status of Safety Conscious Work Environment

Related Condition Report Actions for the Radiation

Protection Department

08/27/2020

13331416, 1345191,

1345335

Preventive Maintenance Change Request

MCRD Spreadsheet

Excel sheet used to track the online and outage control

room deficiencies

Rev. 0

NPG-SPP-03.12

Technical Specifications/Licenses and Amendments

Rev. 0005

NPG-SPP-03.12

Technical Specifications/Licenses and Amendments

Rev. 0004

Operator Work Arounds List of all operator work arounds from 2018 to 2020

Rev. 0

PIC data

Performance indicator data from operations from Sept

2018 through July 2020. (30 records)

08/25/2020

Procedures

0-TI-346

Plant Health Committee and Plant Health Sub-

Committee

Rev. 0051

NPG-SPP-22.001

Effectiveness Reviews

Rev. 0001

0-TI-346

Maintenance Rule Performance Indicator Monitoring,

Rev. 0052

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Trending, and Reporting - 10CFR50.65

NEDP-22

Operability Determinations and Functional Evaluations

Rev. 0021

NPG-SPP-06.2

Preventive Maintenance

Rev. 0013

NPG-SPP-09.16.1

System, Component and Program Health

Rev. 0014

NPG-SPP-22.000

Performance Improvement Program

Rev. 0009

NPG-SPP-22.207

Procedure Use and Adherence

Rev. 0005

NPG-SPP-22.300

Corrective Action Program

Rev. 0019

NPG-SPP-22.300,

Corrective Action Program

Rev. 0012

NPG-SPP-22.300.1

Corrective Action Program (BFN Only),

Rev. 0002

NPG-SPP-22.300.1

Corrective Action Program (BFN Only)

Rev. 0003

NPG-SPP-22.500

Operating Experience Program

Rev. 0011

NPG-SPP-22.600

Issue Resolution

Rev. 0010

OPDP-8

Operability Determination Process and Limiting

Conditions for Operation Tracking

Rev.0024

Self-

Assessments

TVA BFN Work Management Self-Assessment

08/08/2019

Organizational Effectiveness Assessment

2/19/2019

BFN-OPS-SA-19-012

Self-Assessment for SOER 96-01, Control Room

Supervisors

07/12/2019

BFN-SEC-SA-20-001

NRC Baseline Inspection and QA Assessment

11/01/2019

CRP-OTH-FAS-18-001

Focused Self-Assessment Report

07/13/2018

SSA1808

Fire Protection, Browns Ferry Nuclear Plant (BFN)

08/24/2014

SSA1901

Corrective Action, Chattanooga Office Complex (COC),

Browns Ferry (BFN), Sequoyah (SQN) and Watts Bar

Nuclear Plants

01/18/2019

SSA1903

Security and Safeguard Information (SGI), Browns Ferry

Nuclear Plant (BFN)

01/17/2019

SSA1904

Independent Spent Fuel Storage Installation

Chattanooga Office Complex (COC), Browns Ferry

(BFN), Sequoyah (SQN), and Watts Bar (WBN)

03/28/2019

SSA1905

Site Audit Report Operations

05/17/2019

SSA1907

Radiation Protection Browns Ferry Nuclear Plant (BFN)

07/25/2019

SSA1908

Nuclear Fatigue Rule, Browns Ferry Nuclear Plant

09/12/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

(BFN)

SSA1911

Training & Staffing, Browns Ferry Nuclear Plant (BFN),

2/12/2019

SSA2003

Engineering Design Control, Browns Ferry Nuclear Plant

(BFN)

04/06/2020

SSA2004

Site Audit Report, Maintenance

06/06/2020

Work Orders

20260467,

20283885,

114255193,

20575833,

20575834,

119614171,

21019445,

21020922,

119614170,

119614171,120821075,

20592107,

20483130,

20425287,

20383328,

20383321,

20111701,

20009541,

119847417,

119779384,

119678167,

21294904,

21369978,

21369977,

21369979,

21369976,

21369980, 121369981