IR 05000259/2018012

NRC Problem Identification and Resolution Inspection Report 05000259/2018012,05000260/2018012 and 05000296/2018012

ML18276A012
Person / Time
Site:	Browns Ferry
Issue date:	10/03/2018
From:	Masters A NRC/RGN-II/DRP/RPB5
To:	James Shea Tennessee Valley Authority
References
IR 2018012
Download: ML18276A012 (13)

Text

October 3, 2018

SUBJECT:

BROWNS FERRY NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000259/2018012, 05000260/2018012 AND 05000296/2018012

Dear Mr. Shea:

On August 23, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Browns Ferry Nuclear Plant, Units 1, 2, and 3.

On that date, the NRC inspectors discussed the results of this inspection with Mr. Lang Hughes and other members of your staff. The results of this inspection are documented in the enclosed inspection 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 without fear of retaliation through at least one of the several means available.

NRC inspectors documented a finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis of 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 the 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Anthony D. Masters, Chief Reactor Projects Branch 5 Division of Reactor Projects

Docket Nos.: 50-259, 50-260, 50-296 License Nos.: DPR-33, DPR-52, DPR-68

Enclosure:

IR 05000259/2018012, 05000260/2018012 and 05000296/2018012

REGION II==

Docket Numbers:

50-259, 50-260, and 50-296

License Numbers:

DPR-33, DPR-52, and DPR-68

Report Numbers:

05000259/2018012, 05000260/2018012, and 05000296/2018012

Licensee:

Tennessee Valley Authority (TVA)

Facility:

Browns Ferry Nuclear Plant, Units 1, 2, and 3

Location:

Corner of Shaw and Nuclear Plant Road

Athens, AL 35611

Inspection Dates:

August 6, 2018 to August 23, 2018

Inspectors:

W. Deschaine, Resident Inspector, Team Lead

T. Stephen, Senior Resident Inspector

N. Hobbs, Resident Inspector

M. Kirk, Resident Inspector

G. Eatmon, Resident Inspector

S. Ninh, Senior Project Engineer

Approved By:

A. Masters, 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 Problem Identification and Resolution Inspection at Browns Ferry Nuclear Plant, Units 1, 2, and 3 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. NRC and self-revealed findings, violations, or additional items are summarized in the table below.

List of Findings and Violations

Failure to correct an inoperable 250V Shutdown Board Battery Charger Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems

Green NCV 05000296/2018-012-01 Closed None 71153

A self-revealed, Green, NCV of Technical Specifications (TS) 3.8.4 was identified when the licensee failed to correct an inoperable 250V Shutdown Board (SDBD) 3EB Battery Charger on Unit 3. Specifically, in 2014 the 250V SDBD 3EB Battery Charger was entered into the Corrective Action Program (CAP) as a Condition Adverse to Quality (CAQ), but no actions were taken to correct the condition, which led to the component being in inoperable for longer than the allowed outage time defined in TS 3.8.4.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000296/2018-002-00 Inoperable 250V Shutdown Board Battery Charger Results in Condition Prohibited by Technical Specifications 71153 Closed

INSPECTION SCOPE

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.

71152 - Problem Identification and Resolution

Biennial Team Inspection (1 Sample)

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. The assessment is documented below.

(1) Corrective Action Program Effectiveness: Problem Identification, Problem Prioritization and Evaluation, and Corrective Actions - The 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.

(2) Operating Experience and Self-Assessments and Audits - The team evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

(3) Safety Conscious Work Environment - 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.

71153 - Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports

The inspectors evaluated the following licensee event reports (LER) which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) LER 05000296/2018-002-00, Inoperable 250V Shutdown Board Battery Charger Results in Condition Prohibited by Technical Specifications

INSPECTION RESULTS

Corrective Action Program Effectiveness Assessment 71152Problem Identification and Resolution

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.

Operating Experience, Self-Assessments, and Audits Assessment 71152Problem Identification and Resolution

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.

Safety Conscious Work Environment Assessment 71152Problem Identification and Resolution

Based on a sample size of approximately 30 people interviewed from a cross-section of plant employees, 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 the several means available.

However, the team does recognize that the licensee during a 2017 Nuclear Safety Culture (NSC) Self-Assessment in the RP department determined that the NSC was unhealthy resulting in a chilled environment in the RP department. The licensee identified Areas for Improvement (AFIs) and entered them into their CAP. The NRC was unable to determine, at this time, if the corrective actions by the licensee have been effective. The NRC will conduct a follow-up inspection in this area after the licensee has completed their effectiveness reviews.

71153 - Follow-up of Events and Notices of Enforcement Discretion

Failure to correct an inoperable 250V Shutdown Board Battery Charger Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems

Green NCV 05000296/2018-012-01 Closed None 71153

Introduction:

A self-revealed, Green, NCV of Technical Specifications (TS) 3.8.4 was identified when the licensee failed to correct an inoperable 250V Shutdown Board (SDBD)3EB Battery Charger on Unit 3. Specifically, in 2014 the 250V SDBD 3EB Battery Charger was entered into the CAP as a CAQ, but no actions were taken to correct the condition, which led to the component being in inoperable for longer than the allowed outage time as defined in TS 3.8.4.

Description:

The Licensee Event Report (LER) was associated with the Unit 3 250V SDBD 3EB Battery Charger failing its TS required surveillance test on December 22, 2017.

Operations personnel from the licensee placed the spare battery charger in service and exited TS Limiting Conditions for Operation (LCOs) for DC Sources 3.8.4. The licensee determined that a failed firing card in 250V SDBD 3EB Battery Charger was the cause of the failed TS surveillance test. Based on the results from their troubleshooting, a Past Operability Evaluation (POE) was requested on February 5, 2018. The violation of TS was first recognized on February 28, 2018, when the POE determined that the 250V SDBD 3EB Battery Charger, was functional but inoperable from April 3, 2014, until December 22, 2017, which is longer than allowed by TS, thus requiring an LER.

The apparent cause of this event was no Preventive Maintenance (PM) strategy exists to replace or refurbish subcomponents of the SDBD Battery Chargers that are vulnerable to age degradation failures. A lack of precise and rigorous communication between Operations and Engineering personnel in regards to the operability determination of the 3EB Battery Charger in 2014 was a contributing cause.

The inspectors reviewed the licensee event report and determined that the report adequately documented the summary of the event including the cause of the event and potential safety consequences.

Corrective Action(s): As an immediate corrective action, the licensee replaced the firing card in the 250V SDBD 3EB Battery Charger. The licensee also plans to create a PM strategy to replace or refurbish subcomponents of the SDBD Battery Chargers that are vulnerable to similar age degradation failures.

Corrective Action Reference(s): CR 1383682

Performance Assessment:

Performance Deficiency: The failure to correct a condition adverse to quality was a performance deficiency (PD). Specifically, in 2014 the 250V Shutdown Board Battery Charger was entered into the CAP as a CAQ, but no actions were taken to correct the condition until December 22, 2017.

Screening: This performance deficiency was more than minor because it was associated with the mitigating systems cornerstone attribute of equipment performance and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. With the 3EB Battery Charger inoperable the availability and reliability was adversely affected. An evaluation was completed and the Shutdown Board subsystem was considered functional, but inoperable.

Significance: The team used IMC 0609, Attachment 4, Initial Characterization of Findings, issued October 7, 2016, for mitigating systems, and IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, and determined the finding to be of very low safety significance (Green) because the finding was a deficiency that did not represent a loss of safety function. While the charger did not meet the TS Surveillance Requirement to supply the minimum current of 50A at greater than or equal to 210V DC, the charger was capable of fully charging the battery in less than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> because it could provide a current above 27.92A, which was the required current limit for functionality.

Cross-cutting Aspect: No cross-cutting was assigned because it is not indicative of current licensee performance.

Enforcement:

Violation: Browns Ferry Nuclear Plant, Unit 3 TS Subsection 3.8.4, DC Sources - Operating, Condition A requires that with the 3EB Shutdown Board DC electrical power subsystem inoperable, restoration of the 3EB Shutdown Board DC electrical power subsystem is required within 7 days. Condition B requires that if the required action and associated completion time of condition A could not be met then the unit shall be placed 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 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Contrary to the above, the 3EB Shutdown Board DC electrical power subsystem was inoperable from April 3, 2014, to December 22, 2017, and the unit did not enter mode 3 as required in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after exceeding the allowed outage time.

Enforcement Action(s): This violation is being treated as a NCV consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors confirmed that proprietary information was controlled to protect from public disclosure. No proprietary information was documented in this report.

• On August 23, 2018, the inspectors presented the problem identification and resolution inspection results to Mr. Lang Hughes and other members of the licensee staff.

DOCUMENTS REVIEWED

Procedures

BFN-ODM-4.16, Operator Workarounds/Burdens/Challenges, Rev. 0005

COO-SPP-22.305, Level 2 Evaluations (Apparent Cause Evaluation), Rev. 0000

OPDP-1, Conduct of Operations, Rev. 0040

OPDP-8, Operability Determination Process and Limiting Conditions for Operation Tracking,

Rev. 0024

NEDP-22, Operability Determinations and Functional Evaluations, Rev. 0018

NPG-SPP-07.1.4, Work Management Prioritization - On Line, Rev. 0008

NPG-SPP-09.16.1, Component and Program Health, Rev. 0011 System

NPG-SPP-22.000, Performance Improvement Program, Rev. 0008

NPG-SPP-22.001, Effectiveness Reviews, Rev. 0001

NPG-SPP-22.102, NPG Self-Assessment and Benchmarking Programs, Rev. 0005

NPG-SPP-22.300, Corrective Action Program, Rev. 0010

NPG-SPP-22.500, Operating Experience Program, Rev. 0007

0-TI-444(Bases), AIST Program Bases Document, Revision 0006

0-TI-444, Augmented In-service Testing Program, Revision 001

TRN-30, Radiological Emergency Preparedness Training, Revision 38

ECI-0-000-BKR008, Testing and Troubleshooting of Molded Case Circuit Breakers and Motor

Starter Overload Relays, Revision 107

EPIP-5, General Emergency, Revision 54

CAP Training Manual, Revision 5

NPG-SPP-01.7.1, Employee Concerns Program, Revision 3

NPG-SPP-22.600, Issue Resolution, Revision 4

NPG-SPP-07.3.4, Protected Equipment, Revision 4

Condition Reports

1017294

1146001

1146363

1150455

1169573

1119892

1153826

1157981

1158463

1160702

1168726

1170980

1176706

1176922

1195081

201196

204730

212034

219043

21265

21273

28557

249802

298080

249717

249723

253350

268051

281537

286193

233084

294760

1303737

1312984

22394

29543

1331462

1332866

1333906

1336241

1336242

1336246

1340855

1340872

1346131

1347792

1350086

1352009

1354876

1389131

1393879

1402739

1403761

1413619

1413619

1413620

1413621

1413623

20413

23322

23322

27962

1431238

1433902

1436281

1147778

1157182

1157862

1158643

1165935

1170124

258736

266308

267323

284073

285600

28204

29024

1379565

1384056

1384057

1392134

1407222

1419921

20973

1336830

1337825

28204

1337825

1413039

1170978

1189508

237382

268177

1395402

1161179

1161926

1172128

1348588

1385434

1393879

1409305

272790

1153853

1166017

1189404

292179

1353663

1354876

1353667

1354886

233049

1175751

1186857

29794

252195

1336349

1374607

1382275

1389480

1414608

23044

233079

294294

1161911

204735

1159943

1192000

1170978

1131140

1133821

1112692

1170971

1115172

1179483

28065

1385280

260619

1413623

1143588

1143590

1170970

260580

233076

1170968

1179696

1142006

1158499

1163243

1181071

1189810

242311

258637

276753

1314615

1331793

1345723

1145799

1393423

28030

241805

1354876

868804

1383682

Self-Assessments, Audits, and Trend Reports

QA-BF-17-008, Assessment of Security Performance, Browns Ferry Nuclear Plant, March 2-5,

2017

QA-BF-18-001, Security, Browns Ferry Nuclear Plant, June 19, 2018

BFN-OTH-FSA-17-001, Nuclear Safety Culture with Emphasis on Safety Conscious Work

Environment (Rad -Protection), 9/11/2017

BFN-OTH-FSA-17-002, Nuclear Safety Culture with Emphasis on Safety Conscious Work

Environment (Security) 9/11/2017

Site Audit Report SSA1706 Operations Browns Ferry Nuclear Plant (BFN), April 17 - 28, 2017

SSA1804, Site Audit Report Maintenance BFN, April 30 - May 11, 2018

SSA1801, Site Audit Report Materials Management & Procurement Engineering BFN,

January 22 - February 2, 2018

SSA1708, Site Audit Report Radiation Protection BFN, July 31 - August 11, 2017

BFN-PI-FSA-17-001, Nuclear Safety Culture assessment, May 30 - June 12, 2017

BFN-OTH-FSA-17-001, Nuclear Safety Culture with Emphasis on SCWE (Rad-Protection),

August 28 - August 29, 2017

QA-BF-18-006, Unit 3 Refueling Outage BFN, February 17 - April 6, 2018

QA-BF-18-001, BFN-Quality Assurance December Site Report, January 18, 2018

QA-BF-16-018, Unit 1 Outage Assessment (1R11) BFN, October 1, 2016 - November 6, 2016

QA-BF-16-017, Winter Readiness BFN, November 7, 2016 - November 10, 2016

QA-BF-16-003, BFN Operations Fleet Assessment, February 16 - February 19, 2016

Work Orders (WOs)

117339825

117760950

117764640

117821415

117861528

117877268

118304355

118393397

119186157

119371766

119524773

119594233

119639339

119639366

119639704

119676900

119259118

115707718

117595795

117962593

118372021

118433481

118557418

118880286

118880287

118662022

118680184

118680351

118842853

119099221

119259118

119462580

119531837

113729018

117217900

117877268

117638828

117675541

117692872

117770137

117822991

118014100

119408126

119539861

Cancelled Work Orders (WOs)

117977191

117968137

117966837

117967265

117952469

117910853

117822890

117966856

119685837

119130053

118288229

117698103

118152936

118077890

117968137

117888235

117838767

117839581

118330690

117651167

119130053

118660656

118578729

118493283

118237511

118122113

118091807

118061119

119158148

119158087

117648294

117663684

118456896

118225189

118169216

117724905

118027573

117938363

117907703

117907705

Other

System 571 Monitoring Plan

System 82 Health System Report April 2018

General Design Criteria Document, No. BFN-50-7082, Standby Diesel Generators

Outage Control Room Deficiencies, April 7, 2018

BFN Outage and Non-Outage Control Room Deficiencies, June 18, 2018

All Active OWAs Browns Ferry Nuclear, July 10, 2018

OWA Focus Codes: W1, W2, W3, June 18, 2018

Standing Order: OS-201, Rev 0, Interim Guidance on Verifying TS 3.8.6 Specific Gravity Limits,

8/3/2018

Air Conditioning System 031 (a)(1) Plan, Revision 6, Effective 8/18/2016

Air Conditioning System 031 (a)(1) Plan, Revision 7, Effective 5/30/2017

Air Conditioning System 031 (a)(1) Plan, Revision 8, Effective 8/23/2017

Heating and Ventilating Air Flow Diagram, Powerhouse - Turbine Building Unit 2,

Figure 10.12-1, Amendment 25

System Health Report, Unit 0, A/C Heating CREV for date range 10/1/2015-1/31/2016

System Health Report, Unit 0, A/C Heating CREV for date range 2/1/2016-5/31/2016

System Health Report, Unit 0, A/C Heating CREV for date range 6/1/2016-9/30/2016

Management Review Committee (MRC) package for August 23, 2018

Plant Screening Committee (PSC) package for August 20, 2018

Level of Effort Screening for CR 1439272

LER 50-296/2018-002-00, Inoperable 250V Shutdown Board Battery Charger Results in

Condition Prohibited by Technical Specifications, dated April 30, 2018

BFN-Unit 3 Technical Specifications 3.8.4 DC Sources - Operating, Amendment No. 212