IR 05000259/2023001
| ML23122A221 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/03/2023 |
| From: | Louis Mckown Division Reactor Projects II |
| To: | Jim Barstow Tennessee Valley Authority |
| References | |
| IR 2023001 | |
| Download: ML23122A221 (23) | |
Text
SUBJECT:
BROWNS FERRY NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000259/2023001, 05000260/2023001 AND 05000296/2023001
Dear Mr. Barstow:
On March 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Browns Ferry Nuclear Plant. On April 17, 2023, the NRC inspectors discussed the results of this inspection with Mr. Manu Sivaraman and other members of your staff. The results of this inspection are documented in the enclosed report.
One Severity Level IV violation without an associated finding is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
No NRC-identified or self-revealing findings were identified during this inspection.
If you contest the violation or the significance or severity of the violation 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 Nuclear Plant.
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.
May 3, 2023
Sincerely, Louis J. McKown, II, 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:
Report Numbers:
05000259/2023001, 05000260/2023001 and 05000296/2023001
Enterprise Identifier:
I-2023-001-0018
Licensee:
Tennessee Valley Authority
Facility:
Browns Ferry Nuclear Plant
Location:
Athens, Alabama
Inspection Dates:
January 01, 2023 to March 31, 2023
Inspectors:
N. Karlovich, Resident Inspector
B. Kellner, Senior Health Physicist
M. Magyar, Reactor Inspector
A. Nielsen, Senior Health Physicist
K. Pfeil, Resident Inspector
J. Steward, Senior Resident Inspector
Approved By:
Lou J. McKown, II, 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
Severity Level (SL) IV Non-cited Violation (NCV) associated with Licensee Event Report (LER) 2022-001-00 for Browns Ferry Nuclear Plant, Unit 3, Main Steam Relief Valves Lift Settings Outside of Technical Specifications Required Setpoints Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000296/2023001-01 Open/Closed Not Applicable 71153 A self-revealed Severity Level IV NCV of Technical specification (TS) 3.4.3 and TS 3.0.4 was identified when the licensee discovered, through as found test results, that 4 of 13 Main Steam Relief Valves (MSRVs) that were removed for testing had lift settings outside of the +/-
percent setpoint band required for their operability.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000296/2022-001-00 LER 2022-001-00 for Browns Ferry Nuclear Plant,
Unit 3, Main Steam Relief Valves Lift Settings Outside of Technical Specifications Required Setpoints 71153 Closed
PLANT STATUS
Unit 1 began the inspection period at full (100 percent) rated thermal power (RTP). On January 30, 2023, the unit was taken off-line to commence a forced outage (F109) to repair an electro-hydraulic control (EHC) fluid leak on main turbine control valve (MTCV) #2. Following corrective actions, the unit was restarted on February 1, 2023, connected to the electric grid on February 2, 2023, and returned to full RTP on February 6, 2023, where it operated at or near this level for the remainder of the inspection period.
Unit 2 began the inspection period at full RTP. On January 11, 2023, the unit began coastdown in preparation for a planned refueling outage (2R22) which began on February 17, 2023. During the refueling outage, the licensee discovered a cracked weld on the drain valve for reactor recirculation pump A discharge valve. This condition resulted in elevated unidentified floor drain leakage observed during the previous operating cycle. The unit was restarted on March 22, 2023, and returned to full RTP on March 27, 2023, where it operated at or near this level for the remainder of the inspection period.
Unit 3 began the inspection period at full RTP. On January 27, 2023, operators lowered reactor power to 70 percent RTP to complete planned condenser circulating water (CCW) system tube leak repairs to the C2 CCW water box and perform a planned control rod sequence exchange. On January 29, 2023, the unit was returned to full RTP. On February 8, 2023, operators lowered reactor power to 70 percent RTP to perform planned maintenance to repair tube leaks identified on the A2 CCW water box. On February 11, 2023, following completion of planned corrective maintenance, the unit was returned to full RTP, where it operated at or near this level for the remainder 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 activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (2 Samples)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather of a tornado watch on January 3, 2023.
- (2) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather in the form of high winds, heavy rains and potential for tornadoes on February 16, 2023.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 3 Core Spray (CS) Loop I while CS Loop II was undergoing planned maintenance on January 19, 2023.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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) Fire Area 3-1, which includes the Unit 3 Reactor Building NW and SW quadrants on Elevation 519' on January 24, 2023
- (2) Fire Area 26, which includes the Unit 1 Turbine Building Elevations 565' and 604',
Unit 2 Turbine Building Elevation 586', and Unit 3 Turbine Building Elevation 617' on February 2, 2023
- (3) Fire Area 04, which includes the Unit 1, Electrical Board Room 1B Elevation 593 on February 23, 2023
- (4) Fire Area 26, specifically Unit 2 Moisture Separator Room after leaking EHC oil was discovered on March 20 and 21, 2023
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill located in the Unit 1 Mechanical Equipment Room, Control Bay Elevation 606' on January 10, 2023.
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated flooding mitigation protections for the underground cables associated with the residual heat removal service water system in manhole covers 15 and 26 on January 9, 2023
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 February 20 - March 2, 2023:
03.01.a - Nondestructive Examination and Welding Activities.
1. Ultrasonic Testing (UT)
a.
DSC-2-07, Elbow to Elbow, Augmented Exam (observed)b.
GMS-2-24, Pipe to Tee, Class 1 (observed)c.
N10-1, Tee to Safe-end, Class 1 (observed)
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 evolutions:
Unit 1 manual scram, depressurization and cooldown due to EHC system repairs on MTCV #2 as part of F109 on January 30, 2023
Unit 1 control rod withdrawal to criticality and point of adding heat (POAH)following restart from F109 on February 1, 2023
Unit 2 manual scram, depressurization and cooldown as part of entering 2R22 on February 17, 2023
Unit 2 control rod withdrawal to criticality and POAH following restart from
==2R22 on March 21, 2023
==
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a licensed operator requalification training session which included a H2/O2 Analyzer failure, a condensate pump trip, an EHC system leak, a recirculation pump trip, a drywell leak, and a high-power anticipatory transient without scram (ATWS) on the Unit 2 simulator on January 23, 2023. This training session required the crew to enter various abnormal operating instructions (AOI), emergency operating instructions (EOI) and emergency plan implementing procedures (EPIP) to control the plant and appropriately classify the emergency.
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 Common B condensate transfer pump breaker tripped per CRs 1818171 and
===1827523 on February 27, 2023
- (2) Unit 2 reactor recirculation discharge valves A and B body drain valve replacement per work orders 123498959 and 123489241 on March 21, 2023
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01)===
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) Medium site aggregate risk and protected equipment alignment per NPG-SPP-07.3.4, Protected Equipment established for Unit 2 maneuvering power greater than 10 percent per 2-GOI-100-12, Power Maneuvering in preparation for 2R22 on February 17, 2023
- (2) Elevated yellow risk for shutdown cooling within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of shutdown verified protected equipment was in correct alignment per the 2R22 Outage Safety Plan (OSP) on February 18, 2023
- (3) High Risk Evolution (HRE) per National Fire Protection Association (NFPA) 805, per the 2R22 OSP from the period of reactor cavity drain down through reactor pressure vessel (RPV) head fully tensioned on March 11, 2023
- (4) Unit 2, review of risk mitigation plans and the OSP for the 2R22 outage covering February 17, 2023 through March 17, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) During performance of Control Room Air Conditioning System Performance, 0-SR-3.7.4.1(CW A), desired flow was found to be outside of acceptance criteria on February 9, 2023
- (2) Unit 1 HPCI turbine oil leak per CR 1828718 on February 10, 2023
- (3) Unit 3 Standby Liquid Control (SLC) tank slowly rising per CR 1834284 on February 13, 2023
- (4) Unit 3 High Pressure Coolant Injection (HPCI) turbine insulation installed incorrectly per CR 1840358 on March 8, 2023
- (5) Unit 2 pressure boundary Leakage discovered at the body drain valve for reactor recirc A discharge valve, BFN-2-FCV-068-0003 on March 9, 2023
- (6) Unit 2 BFN-2-HCU-085-38-55 was leaking from control rod drive hydraulic control unit water accumulator excessively per CR 1836573 on March 10, 2023
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Unit Common control bay chiller A and B fan fuse permanent reconfiguration per BFN-21-005 on March 23, 2023
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated various activities associated with a planned Unit 2 refueling outage from February 17 through March 22, 2023
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (6 Samples)
- (1) Unit 3 Residual Heat Removal (RHR) pump A shutdown cooling suction valve, 3-MVOP-074-0002 post maintenance testing following the performance of motor operated valve analysis and test system (MOVATS) testing on January 3, 2023
- (2) Emergency Diesel Generator (EDG) B battery charger A low output voltage, not charging batteries following repairs and post maintenance testing per work order (WO) 123392855 on January 19, 2023
- (3) Unit 1 HPCI steam line condensate outboard drain valve, 1-FCV-073-0006B post maintenance testing following diaphragm replacement on January 26, 2023
- (4) Unit 1 MTCV No. 2 emergent repairs following (EHC) oil leak from flared fitting per WO 123442555 on February 3, 2023
- (5) Unit 2 Residual Heat Removal Service Water (RHRSW) Heat Exchanger (HX) 2A Inlet Valve, 2-SHV-023-0031 post maintenance testing following internal valve repair per WO 123523396 on March 8, 2023
- (6) Unit 2 B inboard MSIV, 2-FCV-001-0026 post maintenance testing following refurbishing of needle valve due to leak on dashpot reservoir per WO 123553250 on March 21, 2023.
Surveillance Testing (IP Section 03.01) (6 Samples)
- (1) Unit 2 Reactor Core Isolation Cooling (RCIC) rated flow at normal operating pressure, 2-SR-3.5.3.3, per WO 122525136 on January 4, 2023
- (2) Unit 2 Core Spray Flow Rate Loop II, 2-SR-3.5.1.6(CS II) on January 13, 2023
- (3) Unit 1 reactor cooldown rate monitoring surveillance on February 1, 2023
- (4) Unit 2 reactor cooldown rate monitoring surveillance on February 18, 2023
===122744406 on March 2, 2023
- (6) Unit 2 15-year containment integrated leak rate test (CILRT) on March 27, 2023 Inservice Testing (IST) (IP Section 03.01)===
Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)
- (1) Unit 2 Primary Containment Local Leak Rate Test Recirculation Pump-A Seal Injection for valves 2-CKV-68-508 and 2-CKV-68-550, 2-SI-4.7.A.2-3/68a on February 25, 2023
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) The inspectors reviewed and evaluated the emergency response organization drill response during a Unit 2 Mode 1 scenario that involved on onsite fire lasting greater than 15 minutes, followed by a trip of the reactor recirculation pump concurrent with the loss of torus temperature monitoring capability. This led to the control room operators evaluating the emergency plan implementing procedures to execute required action to make timely notifications of the event to the state and regulatory agency. The scenario continued with a leak developing in the drywell, which found its way into the secondary containment resulting in the crew taking action to emergency depressurize and activate the emergency facilities to assist in setting priorities to mitigate the emergency situation on January 25,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Workers exiting the Radiologically Controlled Area
- (2) Controls for highly radioactive material in the spent fuel pool
Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
(1)2-FCV-68-79 valve maintenance
- (2) Contaminated pipe end grinding in Unit 2 steam tunnel
- (3) Local power-range monitor maintenance (4)2-FCV-68-3 valve maintenance High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) Unit 2 traversing incore probe room
- (2) Refuel floor alternate decay heat removal heat exchanger
- (3) Unit 3 turbine building Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (1 Sample)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
- (1) Main control room emergency ventilation system
Temporary Ventilation Systems (IP Section 03.02) (2 Samples)
The inspectors evaluated the configuration of the following temporary ventilation systems:
- (1) High efficiency particulate air (HEPA) unit 664, steam vault/main steam isolation valve room
- (2) HEPA unit 618, refuel floor contaminated area exit downdraft
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.
Internal Dosimetry (IP Section 03.03) (2 Samples)
The inspectors evaluated the following internal dose assessments:
- (1) Reviewed results of five 'for cause' whole body counting and internal dose assessments performed for follow up to facial contamination or portal monitor alarms.
- (2) Reviewed pre-dive, periodic, and final tritium bioassay results and internal dose assessment of torus divers during October 2022 dive activities.
Special Dosimetric Situations (IP Section 03.04) (3 Samples)
The inspectors evaluated the following special dosimetric situations:
- (1) Reviewed declared pregnant worker records for three workers from February 2021 thru February 2023
- (2) Reviewed extremity dosimetry monitoring results of workers performing Control Rod Drive changeout during the fall 2022 Unit 3 refueling outage.
- (3) Reviewed extremity dosimetry monitoring results of workers performing torus diving during the fall 2022 Unit 3 refueling outage.
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (9 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) Area Radiation Monitors located at various in the Turbine and Reactor Buildings
- (2) Portable friskers located at various locations in the Turbine and Reactor Buildings
- (3) Continuous air monitors located at various locations in the Turbine and Reactor Buildings
- (4) ARGOS-5AB Zeus (beta, gamma, and alpha) personnel contamination monitors located at the main radiologically controlled area exit
- (5) GEM-5 portal type personnel contamination monitors located at the protected area exit
- (6) Portable ion chamber dose rate meters available for use, or in use, in the Unit 2 drywell
- (7) Portable telescoping and auto-ranging Geiger-Mueller (GM) dose rate meters available for use in multiple locations
- (8) Small article/equipment monitors located at the main radiologically controlled area exit
- (9) Air sample counting and analysis equipment (Sodium Iodide, Zinc sulfide, and thin window GM tube) located in the air sample lab
Calibration and Testing Program (IP Section 03.02) (14 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Eberline AMS 4, TVA ID # 860209, 07/20/2021 Eberline AMS 4, TVA ID # 860288, 9/10/2020 and 10/20/2022 Eberline AMS 4, TVA ID # 860396, 11/16/2020 and 10/20/2022
- (2) Canberra iCAM, TVA ID # iCAM 5860, 11/1/2021 and 11/30/2022
- (3) Ludlum 9-3 Ion Chamber dose rate meter, TVA ID # 951572, 3/30/2022
- (4) Ludlum 12 w/43-92 Probe (alpha/beta frisker), TVA ID # 951018, 12/21/2020 and 3/29/2022
- (5) Ludlum Model 177 frisker, TVA ID # 524085, 11/21/2021 and 12/13/2022
- (6) Ludlum Model 3/3A frisker, TVA ID # 951710, 1/25/2021 and 3/16/2022
- (7) Low volume air sampler, TVA ID # 860186, 10/1/2021 and 9/14/2022
- (8) Canberra ARGOS-5AB / Zeus (alpha, beta, gamma) personnel contamination monitor, TVA ID # 00RE90-205, 2/5/2022 and 9/14/2022 Canberra ARGOS-5AB / Zeus (alpha, beta, gamma) personnel contamination monitor, TVA ID # 00RE90-206, 2/9/2022 and 9/22/2022
- (9) Canberra Cronos-4 Small Article Monitor, TVA ID # 00RE90-CR212, 4/22/2022
- (10) Unit 3 Drywell post-accident high range radiation monitors, 3-RM-90-272A and 3-RM-90-273A
- (11) Main Control Room Radiation Monitor, 0-RM-090-008
- (12) Unit 3 Reactor Building ventilation exhaust radiation monitor, 3-RM-250
- (13) Counting Room Gamma Spectroscopy Systems - Detector 11 and Detector 12
- (14) Eberline SAM-11 Small Article Monitor, TVA ID # 841990, 8/2/2022 Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (3 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) Liquid Radioactive Waste radiation monitor, 0-RM-90-130
- (2) Main Stack Radiation Monitor, 0-RM-147 and 148
- (3) Plant Vent Stack Wide Range Gaseous Effluent Monitoring System, 0-RE-90-93, 0-RE-90-98A, and 0-RE-90-98B (Normal, Mid, and High range)
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===
- (1) Unit 1 (January 1, 2022 through December 31, 2022)
- (2) Unit 2 (January 1, 2022 through December 31, 2022)
- (3) Unit 3 (January 1, 2022 through December 31, 2022)
BI02: RCS Leak Rate Sample (IP Section 02.11) (3 Samples)
- (1) Unit 1 (January 1, 2022 through December 31, 2022)
- (2) Unit 2 (January 1, 2022 through December 31, 2022)
- (3) Unit 3 (January 1, 2022 through December 31, 2022)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) March 5, 2022 through March 17, 2023 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) January 1, 2022 through January 31, 2023
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
- (1) Corrective actions and work order associated with 2C inboard main steam isolation valve (MSIV) 2-FCV-1-37 failed stroke time criteria for technical specification (TS)surveillance requirement 3.6.1.3.6 on February 18, 2023.
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 50-296/2022-001-00 for Browns Ferry Nuclear Plant, Unit 3, Main Steam Relief Valve Lift Setting Outside of Technical Specifications Required Setpoints. The inspection conclusions associated with this LER are documented in this report under the Inspection Results Section.
INSPECTION RESULTS
Severity Level (SL) IV Non-cited Violation (NCV) associated with Licensee Event Report (LER) 2022-001-00 for Browns Ferry Nuclear Plant, Unit 3, Main Steam Relief Valves Lift Settings Outside of Technical Specifications Required Setpoints Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000296/2023001-01 Open/Closed Not Applicable 71153 A self-revealed Severity Level IV NCV of Technical specification (TS) 3.4.3 and TS 3.0.4 was identified when the licensee discovered, through as found test results, that 4 of 13 Main Steam Relief Valves (MSRVs) that were removed for testing had lift settings outside of the +/-
3 percent setpoint band required for their operability.
Description:
The Browns Ferry Unit 3 TS 3.4.3 requires 12 of the 13 MSRVs to be operable while in Modes 1, 2, and 3. On May 10, 2022, the Tennessee Valley Authority was notified of as-found testing results that four MSRVs from Unit 3 were outside of the +/-3 percent setpoint band required for operability. It was determined that these MSRVs failed due to corrosion bonding to the valve seats and non-quantifiable leakage known as simmering. More than one MSRV was considered to be inoperable during the entire operating cycle from March 25, 2020 to February 26, 2022 and longer than permitted by TS. Additionally, TS 3.0.4 requires that when a limiting condition for operation (LCO) is not met, entry into an applicable Mode or specified condition is not permitted unless the associated actions permit continued operation. On two separate occasions (April 3, 2020 and April 5, 2020) following a forced outage to perform repairs on unrelated equipment, the licensee entered a TS 3.4.3 applicable Mode when the required actions for continued operation were not met.
The affected valves remained capable of maintaining reactor pressure below the American Society of Mechanical Engineers code limit of 1375 psig. All 13 of the MSRV pilot valves have been replaced during the Unit 3 Spring 2022 refueling outage.
Corrective Actions: The licensee replaced all 13 MSRV pilot valves during the Spring 2022 refueling outage. As left testing verified that these refurbished pilot valves were within +/- 1 percent of their setpoints. As most recently discussed in LER 50-260/2021-002-00, a flaking issue has been noted with the platinum coated pilot discs. The Boiling Water Reactor Owners Group (BWROG) is continuing to work toward a solution to improve the quality and adhesion of the platinum coating on the discs. The corrective actions suggested by the BWROG will be incorporated by BFN as part of CA 1775232-003, to correct setpoint drift. To reduce the probability of seat leakage occurring in the future, pilot seat rebuilds will be performed in valves that have low stellite in the seat. In addition, on March 30, 2023, BFN submitted a BWROG endorsed technical specification request for amendment for NRC review and approval that revises the performance frequency of existing MSRV surveillance requirements and provides an alternative to demonstrate the capability of the relief valves to open when manually actuated during startup.
Corrective Action References: CRs 962223, 1286467, 1410577, 1521190, 1658693, 1699286, and 1775232
Performance Assessment:
The NRC determined this violation was not reasonably foreseeable and preventable by the licensee and therefore is not a performance deficiency.
Inspectors reviewed vendor procedure, "NWS-R-72, NWS Technologies Repair of Browns Ferry Target Rock "Interim" 2-Stage Main Steam Safety Relief Valves, Rev 3", used to rebuild the pilot valve and main valve disc assemblies and concluded the procedure was satisfactory.
Significance: A regional Senior Reactor Analyst (SRA) performed a bounding risk assessment of the underlying condition using SAPHIRE 8 Version 8.2.8 and the Browns Ferry Unit 3 Standardized Plant Analysis Risk (SPAR) model version 8.80, dated May 26, 2022. The SRA conservatively set the exposure time to a maximum of one year. Since BFN-3-PCV-001-0022 lifted above system design pressure, this valve considered to be unable to perform its American Society of Mechanical Engineers (ASME) code or Probabilistic Risk Assessment (PRA) function and was set to be true. The PRA function success criteria is that 11 of 13 relief valves open upon demand. The remaining three out of tolerance valves would open well below the system design pressure, but greater than the 3 percent above the technical specification lift set point. The calculation of record shows if 11 of 13 safety relief valves open by +3 percent of their technical specification lift points, maximum system pressure will remain below 110 percent of design pressure and meet ASME code function. Therefore, for safety relief valves BFN-3-PCV-004, 034, and 041, the SRA considered that each Browns Ferry operating unit has a non-safety related electrical logic system (MSRV Actuation Logic) installed, which provides defense in depth against MSRV setpoint drift by electrically opening MSRV groups based upon setpoints at 1135 psig, 1145 psig and 1155 psig. The SRA conservatively adjusted the failure probability from a nominal failure probability of 2.11 E-3 to 2.5 E-1, using engineering judgement since the oxide binding only affected the pilot valve mechanical lift setpoint and not the operation of the main valve. The dominant accident sequence would be a plant transient caused by a main steam isolation valve going closed, with a failure of the Reactor Protection System (RPS) to trip the unit and 3 safety relief valves failing to open electrically or mechanically such that system pressure exceeded 110 percent of design pressure. The resulting change in core damage frequency was less than 1.0 E-6 corresponding to a finding of very low safety significance (Green).
Enforcement:
This violation is characterized as a Severity Level IV NCV based on its similarity to SLIII example 6.1.c.1 in the Enforcement Policy.
Severity: This issue is considered within the traditional enforcement process because there was no performance deficiency associated with the violation of NRC requirements. Inspection Manual Chapter (IMC) 0611, "Power Reactor Inspection Reports," Section 11 states, in part, that "traditional enforcement is used to disposition violations receiving enforcement discretion or violations without a performance deficiency". The inspectors also reviewed NRC Enforcement Policy, Section 2.2.1, Factors Affecting Assessment of Violations", which states, in part, that "whenever possible the NRC uses risk information in assessing the safety significance of violations". Accordingly, after considering that the condition represented very low safety significance, the inspectors concluded that the violation would be best characterized as Severity Level IV under the traditional enforcement process.
Violation: Browns Ferry Nuclear Plant, Unit 3 TS LCO 3.4.3 requires the safety function of 12 S/RVs shall be operable in Modes 1, 2, and 3. Subsection 3.4.3, 'Safety/Relief Valves (S/RVs),' Condition A, requires 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 25, 2020 to February 26, 2022, 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.
Browns Ferry Nuclear Plant, Unit 3 TS Section 3.0, 'LCO Applicability', Subsection LCO 3.0.4, requires, in part, that when an LCO is not met, entry into a mode or other specified condition in the applicability shall only be made when the associated actions to be entered permit continued operation in the mode or other specified condition in the applicability for an unlimited period of time. Contrary to the above, on April 3, 2020 and April 5, 2020, Unit 3 entered a TS 3.4.3 applicable mode when LCO TS 3.4.3 required actions were not met.
Enforcement Action: This violation is being treated as a 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 April 17, 2023, the inspectors presented the integrated inspection results to Mr.
Manu Sivaraman and other members of the licensee staff.
On March 2, 2023, the inspectors presented the Inservice Inspection Exit Meeting inspection results to Manu Sivaraman, Site VP and other members of the licensee staff.
On March 17, 2023, the inspectors presented the Radiation protection inspection exit meeting inspection results to Manu Sivaraman and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
0-AOI-100-7
Severe Weather
Rev 50
Drawings
3-47E814-1
Flow Diagram Core Spray System
Rev 35
3-OI-75
Core Spray System
Rev 78
3-OI-75/ATT-1
Core Spray System Attachment 1 Valve Lineup Checklist
Rev 55
3-OI-75/ATT-2
Core Spray System Attachment 2 Panel Lineup Checklist
Rev 56
3-OI-75/ATT-3
Core Spray System Attachment 3 Electrical Lineup Checklist
Rev 56
3-OI-75/ATT-4
Core Spray System Attachment 4 Instrument Inspection
Checklist
Rev 55
Procedures
BFN-ODM-4.18
Protected Equipment
Rev 31
FPR Appendix F -
FA 04
NFPA 805 Fire Protection Report Appendix F Fire Area 04
Rev 4
Fire Plans
FPR-Volume 2
Fire Protection Report Volume 2
Rev 74
Miscellaneous
00082402
Fire Drill Evaluation Report for U1 Control Bay Mechanical
Equipment Room
01/10/2023
NPG-SPP-18.4.7
Control of Transient Combustibles
Rev 17
Procedures
OPDP-3
Administration Of Pre-fire Plans, Fire Emergency Response,
and Development/Evaluation of Fire Drills
Rev 0
Corrective Action
Documents
CR 1827993
01/09/2023
Engineering
Evaluations
B43060127001
Moisture Impervious Medium Voltage Cable
01/31/2006
Miscellaneous
SS-E12.6.02
5-15kv Cable, Moisture Impervious, Ethlyene-Propylene
Rubber Insulated
Rev 1
Work Orders
and 119297170
Miscellaneous
H2/02 Analyzer Failure, Condensate Pump Trip EHC leak,
Rev 0
1-AOI-100-1
Reactor Scram
Rev 32
Procedures
1-GOI-100-12A
Unit Shutdown from Power Operation to Cold Shutdown and
Reductions in Power During Power Operations
Rev 40
Engineering
Changes
BFN 23-018
Unit 2 Reactor Recirculation FCV-68-3 Drain Line
Replacement and Plug
Rev 0
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
Miscellaneous
Unit 2 2R22
Outage Safety
Plan
Unit 2 Cycle R22 Outage Safety Plan
Rev 0
2-GOI-100-12
Power Maneuvering
Rev 50
Procedures
NPG-SPP-07.3.4
Protected Equipment
Rev 13
1833383
2/09/2023
CR 177206
CR 1828718
CR 1834284
Corrective Action
Documents
CR 1836573
Engineering
Evaluations
PDO 1507015
Prompt Determination of Operability for CR 1507015
04/12/2019
Miscellaneous
EPRI TR-100759
Terry Turbine Maintenance Guide, HPCI application
11/2002
0-SR-3.7.4.1(CW
A)
Control Room Air Conditioning System Performance
Rev 1
3-SR-3.1.7.3
SLC SYS Enriched Sodium Pentaborate (SPB) Solution
Concentration, Quantity Calculation, and ATWS Equivalency
Calculation
Rev 55
Procedures
OPDP-8
Operability Determination Process and Limiting Conditions
for Operations Tracking
Rev 30
2281694
2/09/2023
Work Orders
Corrective Action
Documents
1788301
03/23/2023
Engineering
Changes
BFN-21-005
Control Bay Chiller Fan Fuses
Rev 1
Calibration
Records
Calibration
Certificate
250655
Report of Calibration for Fluke infrared thermometer E59812
11/17/2022
26922
1830955
01/24/2023
Corrective Action
Documents
1839434,
1839439
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ANSI/ANS-56.8-
2002
Containment System Leakage Testing Requirements
11/27/2002
Miscellaneous
BFN-50-7071
Reactor Core Isolation Cooling System Design Criteria
Document
Rev 23
1-SR-3.3.3.1.4(G)
Verification of Remote Position Indicators for High Pressure
Coolant Injection System Valves
Rev 7
1-SR-3.4.9.1.(1)
Reactor Heatup and Cooldown Rate Monitoring
Rev 14
1-SR-3.5.3.3
RCIC System Rated Flow at Normal Operating Pressure
Rev 48
1-SR-
3.6.1.3.5(HPCI)
HPCI System Motor Operated Valve Operability
Rev 26
2-SI-4.7.A.2-
3/68a
Primary Containment Local Leak Rate Test Recirculation
Pump-A Seal Injection: Penetration X-37C
Rev 16
2-SI-4.7.A.2.a-f
Primary Containment Integrated Leak Rate Test
Rev 17
2-SI-4.7.A.2.a-f
Primary Containment Integrated Leak Rate Test
Rev 16
2-SR-3.4.9.1(1)
Reactor Heatup and Cooldown Rate Monitoring
Rev 29
2-SR-
3.5.1.6(RHR I)
Quarterly RHR System Rated Flow Test - Loop I
Rev 49
Procedures
2-SR-3.5.3.3
RCIC System Rated Flow at Normal Operating Pressure
Rev 79
23390778 and
23392855
01/19/2023
23553250
03/21/2023
WO 122378622
2/18/2023
Work Orders
01/04/2023
CR 1807401
CR 1820842
Corrective Action
Documents
CR 1842611
Corrective Action
Documents
Resulting from
Inspection
CR 1839367
Procedures
NISP-RP-004
Radiological Posting and Labeling
Rev 1
Radiation
Surveys
M-20221006-33
M0113 Unit 1 RXB 565' A&C RHR Hx Room
10/06/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
FP-0-000-INS027
Self Contained Breathing Apparatus
Rev 19
BFN Trend Analysis of In-Vivo Measurements [Semi-Annual
evaluation including random whole body counts] January
21 through December 2022
Various
Calculations
R38 230125 1063
Browns Ferry Nuclear Plant (BFN) - Prospective
Determination for Occupational Exposure Calendar Year
22
01/25/2023
Corrective Action
Documents
Condition Reports (CRs) 1729768, 1741186, 1743964,
1754023, 1756829, 1756905, 1758176, 1764395,1764740,
1771144, 1772646, 1781121, 1807415, 1808265, 1813387,
and 1828855
Various
2-011
Dosimetry Investigation Report (DIR) for CR 1756772
2/23/2022
2-096
DIR for CR 1816731
11/14/2022
Miscellaneous
NVLAP LAB
CODE: 100518-0
Vendor dosimetry provider National Voluntary Laboratory
Accreditation Program (NVLAP) Certificate of Accreditation
for the period 01/10/2021 through 12/31/2023
Various
Self-Assessments 1605001
Dosimetry Self Assessment
10/03/2020
Corrective Action
Documents
Condition Reports (CRs) 1755731, 1695165, 1705606,
1738589, 1739622, 1744743, 1735682, 1760402, 1776558,
1782357, 1808091, 1810217, 1824302, and 1828623
Various
Miscellaneous
Browns Ferry Nuclear Plant Quarterly Instrument Failure
Report [RP Portable and semi-fixed instruments], January
21 through December 2022.
Various
119696113
Work Order # 119696113, Wide Range Gaseous Effluent
Radiation Monitor System Mid & High Range Calibration, 0-
RE-90-98A and 98B
01/30/2020
20133661
Work Order # 120133661, Wide Range Gaseous Effluent
Radiation Monitor System Normal Range Calibration, 0-RE-
90-093
07/08/2020
20899316
Work Order # 120899316, Containment High Range
Radiation Monitor Calibration, 3-RM-90-272A
11/23/2021
21296047
Work Order# 121296047, Main Stack Effluent Radiation
Monitor Calibration, 0-RM-90-147 and 148
10/29/2021
Work Orders
21379766
Work Order # 121379766, Liquid Rad Waste Monitor
10/18/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calibration, 0-RM-90-130
21682683
Work Order # 121682683, Containment High Range
Radiation Monitor Calibration, 3-RM-90-273A
09/13/2022
2418232
Work Order# 122418232, Main Stack Effluent Radiation
Monitor Calibration
01/27/2023
Condition Reports (CRs) 1661007, 1796759, 1803731,
1810217, 1811440, 1817265, and 1841724
Various
Corrective Action
Documents
CR 1840376
BFN 2021 Annual Radioactive Effluent Release Report
05/02/2022
22 Liquid and Gas Maximum Dose Summary Report
(entire year)
01/19/2023
January 2023 Liquid and Gas Maximum Dose Summary
Report (year to date)
01/30/2023
Miscellaneous
BFN 2020 Annual Radioactive Effluent Release Report
04/30/2021
71151
Work Orders
2425905,
2418649,
249253,
2454002,
2426039
Corrective Action
Documents
1836565
2/18/2023
Drawings
2-730E927-10
Rev 21
Procedures
2-SI-5.5.6(MSIV)
Main Steam Isolation Valve Stroke Time Test
Rev 5
71152A
Work Orders
2097702
Implement temporary modification to install a DC to DC
converter (Tmod BFN-2-2021-001-003)
2/18/2023
Corrective Action
Documents
2223, 1286467,
1410577,
21190,
1658693,
1699286, and
1775232