IR 05000260/2025040

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95001 Supplemental Inspection Report 05000260/2025040 and Follow-Up Assessment Letter
ML25079A182
Person / Time
Site: Browns Ferry Tennessee Valley Authority icon.png
Issue date: 03/24/2025
From: Louis Mckown
NRC/RGN-II/DORS/EB1
To: Erb D
Tennessee Valley Authority
References
EA-24-075 IR 2025040
Download: ML25079A182 (1)


Text

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNIT 2 - 95001 SUPPLEMENTAL INSPECTION REPORT 05000260/2025040 AND FOLLOW-UP ASSESSMENT LETTER

Dear Delson Erb:

On February 13, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed a supplemental inspection at Browns Ferry Unit 2, using Inspection Procedure (IP) 95001,

"Supplemental Inspection Response to Action Matrix Column 2 (Regulatory Response) Inputs, and discussed the results of this inspection and the implementation of the stations corrective actions with Daniel Komm, Site Vice President, and other members of your staff.

The NRC performed this inspection to review the stations actions in response to a White finding in the Mitigating Systems cornerstone which was documented and finalized in NRC Inspection Report 05000260/2024091. On January 15, 2025, the NRC was informed that the station was ready for the supplemental inspection.

The NRC determined that your staffs evaluation identified the cause of the White finding.

Specifically, the organization failed to identify that the overpressurization of the high pressure coolant injection (HPCI) steam exhaust line rupture disc on December 15, 2021, exceeded the operating ratio and lower bound of the burst pressure, damaging the rupture disc membrane and resulting in the failure of the rupture disc during a normal surveillance procedure.

The inspectors concluded the corrective actions to preclude repetition of the root and contributing causes of the White finding were effective and adequately prioritized considering safety significance and regulatory compliance. In addition, the inspectors determined that evaluations were documented at a sufficient level of detail, included relevant operating experience, and identified the root causes, extent of conditions, and extent-of-causes of the performance issue. Based on the results of the inspection, the inspectors concluded that the objectives of the IP 95001 supplemental inspection were met.

The NRC determined that completed or planned corrective actions were sufficient to address the performance issue that led to the White finding previously described. Therefore, the performance issue will be closed and no longer considered as an Action Matrix input as of the date of the exit meeting. Based on the guidance in Inspection Manual Chapter 0305, Operating Reactor Assessment Program, and the results of this inspection, the NRC has determined that Browns Ferry Unit 2 will transition to the Licensee Response Column (Column 1) of the Action Matrix as of February 13, 2025.

March 24, 2025 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, Louis J. McKown, II, Chief Projects Branch 5 Division of Operating Reactor Safety Docket No. 05000260 License No. DPR-52

Enclosure:

As stated

Inspection Report

Docket Number:

05000260

License Number:

DPR-52

Report Number:

05000260/2025040

Enterprise Identifier:

I-2025-040-0002

Licensee:

Tennessee Valley Authority

Facility:

Browns Ferry Nuclear Plant, Unit 2

Location:

Athens, Alabama

Inspection Dates:

February 10, 2025 to February 13, 2025

Inspectors:

C. Curran, Resident Inspector

B. Towne, Senior Resident Inspector (Team Lead)

Approved By:

Louis J. McKown, II, Chief

Projects Branch 5

Division of Operating Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) reviewed the licensees corrective actions to address a White finding by performing a supplemental inspection at Browns Ferry Nuclear Plant, Unit 2, using Inspection Procedure (IP) 95001, Supplemental Inspection Response to Action Matrix Column 2 Inputs, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

Type Issue Number Title Report Section Status NOV 05000260/2024090-01 Browns Ferry Unit 2 HPCI Rupture Disc Failure EA-24-075 95001 Closed

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the 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.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

===95001 - Supplemental Inspection Response to Action Matrix Column 2 (Regulatory Response) Inputs The inspectors reviewed and selectively challenged aspects of the licensees problem identification, causal analysis, and corrective actions in response to a White finding and associated Notice of Violation (NOV) of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," when the licensee failed to promptly identify and correct a degraded condition with the Unit 2 high pressure coolant injection (HPCI) turbine exhaust inner rupture disc after pressurizing the HPCI steam exhaust line. The final significance determination of the White finding and NOV are documented in NRC inspection reports 05000260/2024090 dated September 17, 2024 (Agency Documents Access and Management (ADAMS) Accession Number ML24255A027), and 05000260/2024091 dated November 21, 2024 (ADAMS Accession Number ML24310A203).

1. Objective: Ensure that the root and contributing causes of individual and collective White

performance issues are understood.===

Under this objective, the inspectors reviewed the root cause evaluations the licensee conducted for the licensees failure to identify and correct a degraded condition with the Unit 2 HPCI turbine exhaust inner rupture disc after pressurizing the HPCI steam exhaust line which resulted in the unplanned isolation of HPCI and the discovery of the loss of the associated safety function. Their review consisted of an evaluation of the following: the licensee's identification of the issue(s), when and how long the issue(s) existed, prior opportunities for identification, documentation of significant plant-specific consequences and compliance concerns, use of systematic methodology to identify causes with a sufficient level of supporting detail, consideration of prior occurrences, identification of extent-of-condition and extent-of-cause, and identification of any potential programmatic weaknesses in performance.

NRC Assessment: The team concluded that this objective was met. The licensees root cause evaluation (RCE) determined that the organization failed to identify that the overpressurization of the HPCI steam exhaust line rupture disc on December 15, 2021, exceeded the operating ratio and lower bound of the burst pressure, damaging the rupture disc membrane and resulting in the failure of the rupture disc during a normal surveillance procedure.

a.

Identification. On March 19, 2024, the Unit 2 HPCI turbine exhaust inner rupture disc failed during surveillance testing resulting in the unplanned isolation of the HPCI system and loss of the associated safety function. The event was initially addressed using a Level 2 RCE which incorrectly concluded that the rupture disc was defective upon receipt and the licensee issued a 10CFR Part 21, "Reporting of Defects and Noncompliance," notification. During an NRC inspectors review, an overpressurization of the HPCI turbine steam exhaust line on December 15, 2021, was discovered. The licensee upgraded the significance level of the investigation to Level 1 to perform a more comprehensive review of the events and circumstances of the rupture disc failure, and the Part 21 notification was retracted. The maximum pressure experienced by the rupture disc during the December 15th event exceeded the lower range of the burst tolerance and the operating ratio of the rupture disc as recommended by the manufacturer. Failure evaluation of the rupture disc determined that the disc failed prematurely due to cyclic fatigue as a result of being partially deformed by the overpressurization. Per the Level 1 RCE, the licensee stated that the failure to identify and correct a condition adverse to quality with the rupture disc due to its overpressurization was NRC-identified.

b.

Exposure Time. The failure analysis determined that the disc was weakened by cyclic stresses affecting the rupture disc following each HPCI surveillance. As such, the most recent successful HPCI surveillance was determined to be the point in time that the cyclic stresses weakened the rupture disc to the point it would result in failure during the next HPCI run. The exposure time was determined to be December 22, 2023, through March 23, 2024, equivalent to 92 days. The inspector determined that the exposure time was appropriately assessed.

c.

Identification Opportunities. The licensee appropriately identified two identification opportunities that were missed. The HPCI exhaust overpressurization that is documented in condition report (CR) 1742531 describes the event that led to deformation of the rupture disc and its eventual failure due to cyclic fatigue. The engineering judgment following this event failed to consider the operating ratio of the rupture disc and failed to recognize that the rupture disc had been structurally affected.

A second opportunity to identify the issue was during the Level 2 RCE when the station incorrectly assumed that the rupture disc was defective upon installation. The licensee generated CR 1964751 to evaluate why the station had failed to identify the correct cause during its Level 2 RCE.

d.

Risk and Compliance. The licensee performed a Safety Consequences Evaluation and did not identify any weaknesses to the defense-in-depth of nuclear safety. Although the event resulted in the unplanned inoperability and unavailability of the single train of the Browns Ferry Nuclear Plant (BFN) Unit 2 HPCI system, the reactor core isolation cooling (RCIC) system remained operable, and all other emergency core cooling system and automatic depressurization system valves were available to facilitate core cooling.

Based on this, sufficient systems were available to provide the required safety functions needed to protect the health and safety of the public. Additionally, no weaknesses were identified in the defense-in-depth to industrial safety, radiation safety, or environmental safety. Inspectors concluded that the licensee appropriately understood the risk and compliance.

e.

Methodology. The Level 1 RCE employed a systematic evidence-based methodology to determine the root and contributing causes of the White finding and the HPCI unplanned inoperability. The primary method used in the analysis was Event and Causal Factors Analysis Charting. Inspectors assessed the analysis methodology as appropriate.

f.

Level of Detail. The inspectors determined the Level 1 RCE was performed commensurate with the safety significance and complexity of the performance issue and was of sufficient detail to identify the root and contributing causes, extent-of-condition, and extent-of-causes. The RCE team utilized a formal cause analysis process to identify the problems and determine corrective actions.

g.

Operating Experience. Inspectors determined that the licensee appropriately considered operating experience (OE) during the root cause evaluation. Several industry OE events involving rupture disc failures provided insights to the licensee for preventing reoccurrence.

h.

Extent-of-Condition and

Cause.

The licensee used the same object - same application, same object - other application, similar object - same application, and similar object - other application methodologies to evaluate the extent-of-condition and the extent-of-cause. The inspectors reviewed the safety culture traits in NUREG-2165, Safety Culture Common Language, referenced in IMC 0310-06, "Cross-Cutting Areas and Aspects," to determine if these were appropriately considered during the licensees evaluations of the root causes, extent of conditions, and extent-of-causes.

i.

Common

Cause.

No common causes were identified by either the licensee or the inspectors.

2. Objective: Ensure that the extent-of-condition and extent-of-cause of individual and

collective White performance issues are identified. (1 Sample)

Under this objective, the inspectors independently assessed the BWXT failures analysis, the Events and Causal Factor Chart, the Cause Test Evaluation, and the Safety Consequences Event Evaluation to assess the licensee's extent-of-condition and extent-of-cause.

NRC Assessment: The team concluded that this objective was met. The extent-of-condition was evaluated considering rupture discs and their applications throughout the Tennessee Valley Authority (TVA) fleet. Rupture discs that are not installed in steam systems do not undergo cyclic pressure and temperature loading and are therefore not susceptible to the turtle backing and fatigue stress failure mechanism identified in the analysis. The extent-of-condition is limited to rupture discs installed in HPCI and RCIC systems at Units 1, 2, and 3 at Browns Ferry. Omission of the operational ratio data from the vendor manuals, plant drawings, and plant operating procedures was applicable to each of the rupture discs in question. The RCE evaluated if similar rupture disc defects may exist in the applicable systems by determining if any event had taken place in which personnel may have failed to identify that the operational limit of the rupture discs was exceeded. The analysis did not identify any other steam exhaust overpressurization events which could have exceeded the operating ratio for the other systems. The corrective action plan for the HPCI failure includes adding the operating ratio data to vendor manuals, plant drawings, and plant procedures for all of the vulnerable components. Inspectors judged that the corrective action plan sufficiently addresses the equipment reliability attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Extent-of-Condition and

Cause.

The licensee used the same object - same application (Tier 1), same object - similar application (Tier 2), similar object - same application (Tier 3), and similar object - similar application (Tier 4) methodologies to evaluate the extent-of-condition and the extent-of-cause. The Tier 1 application evaluated for any event in which BFN personnel failed to identify that the operation ratio of a rupture disc was exceeded. Analysis ruled out the susceptibility of rupture discs in all system except HPCI and RCIC, which are the only systems that are susceptible to the failure mechanism of fatigue stress following exposure to pressure exceeding the operating ratio. No additional overpressurization events were identified for the susceptible components since installation. The Tier 2 application evaluated rupture discs for other applications. The failure mechanism experienced by HPCI following the overpressure event was deemed to not be credible for rupture discs in non-steam systems that do not experience cyclic pressure and temperature loading. The Tier 3 application evaluated for other operational limitations for rupture discs that may be unknown to plant personnel. No additional unknown component limitations were identified. The Tier 4 application evaluated for unknown operational limitations for rupture discs in all applications.

The review and revision of vendor technical manuals to prevent the omission of pertinent information is included as part of the corrective action plan. Using IP 95001, the inspectors determined that the licensee appropriately identified the extent-of-condition and extent-of-cause in the RCE.

3. Objective: Ensure that completed corrective actions to address and preclude repetition of

White performance issues are timely and effective. (1 Sample)

Under this objective, the inspectors assessed the appropriateness and timeliness of the licensee's corrective actions.

NRC Assessment: The team concluded that this objective was met. Inspectors determined that corrective actions are timely and adequate to prevent recurrence.

a.

Completed Corrective Actions to Prevent Recurrence

i. Corrective Actions

to Prevent Recurrence (CAPRs) 1917980-026, 1917980-027:

Revise Vendor Manual BFN-VTD-F103-0050, "Installation and Maintenance Instructions for Fike Rupture Disc Assemblies," to include all pertinent operating limits for operating rupture discs on HPCI and RCIC systems. This CAPR addresses the root cause and first contributing cause of the event. The root cause was determined in the licensee analysis to be that the operating ratio was not utilized to develop effective operating limits to protect the integrity of the rupture disc. The first contributing cause was that the existing vendor manual for the HPCI rupture disc did not have all the available pertinent information on the operating limits for the rupture disc. CAPR 1917980-026 and -027 address these causes by revising the vendor manual with the appropriate information. These actions were completed prior to the commencement of the 95001 inspection and verified by the inspectors.

ii.

CAPR 1917980-028: Create or Revise a design output document to determine the operating pressure limit for the HPCI and RCIC system turbine exhaust line rupture discs. This CAPR addresses the root cause of the event. The design output document was reviewed by inspectors and judged sufficient to establish operating pressure limits for the HPCI and RCIC system turbine exhaust lines that would preclude exceeding the operating ratio of the rupture discs. This action was completed prior to the commencement of the 95001 inspection and verified by the inspectors.

iii.

CAPR 1917980-029: Revise the following drawings to update the "NOTES" section to specify the operating pressure limit for the turbine exhaust line rupture discs.

  • 1-, 2-, 3-47E610-73-1, Mechanical Control Diagram HPCI System
  • 1-, 2-, 3-47E610-71-1, Mechanical Control Diagram RCIC System This CAPR addresses the root cause of the event. The above drawing changes incorporated the operating pressure limit for the HPCI and RCIC system turbine exhaust line from CAPR 1917980-028. Updating the "NOTES" section into the pertinent plant drawings that operators would use for reference establishes a pressure limit to prevent exceeding the operating ratio of the rupture discs. This action was completed prior to the commencement of the 95001 inspection and verified by the inspectors.

iv.

CAPR 1917980-030: Revise the following procedures to specify the operating pressure limit for the turbine exhaust line rupture discs.

[Note: Changes for Section 3.0, Precautions and Limitations, and Section 8.3, RCIC Turbine Trip]

  • 1-, 2-, 3-OI-73, High Pressure Injection System

[Note: Changes for Section 3.0, Precautions and Limitations, and Section 8.3, HPCI Turbine Trip]

  • 1-, 2-, 3-ARP-9-3B, Alarm Response Procedure

[Note: Change for Window 28 alarm response (RCIC Turbine Trip)]

  • 1-, 2-, 3-ARP-9-3F, Alarm Response Procedure

[Note: Change for Window 25 alarm response (HPCI Turbine Trip)]

This CAPR addresses the root cause of the event. The above procedure changes incorporated the operating pressure limit for the HPCI and RCIC system turbine exhaust line from CAPR 1917980-028. Applicable sections were updated in the pertinent plant procedures that operators would use for reference establishes a pressure limit to prevent exceeding the operating ratio of the rupture discs were updated. This action was completed prior to the commencement of the 95001 inspection and verified by the inspectors.

b.

Other Completed Corrective Actions i.

Corrective Action (CA) 1917980-049, 050, 051: Perform benchmark of vendor manual programs to determine if TVA is aligned with industry standards; review rupture disc vendor manuals at Sequoyah and Watts Bar Nuclear Plants to ensure all pertinent operating limits for rupture discs installed in safety-related systems are included in the vendor manual as necessary. This action addresses the first contributing cause. The vendor manual for the HPCI rupture disc at the time of the overpressure event did not contain all the pertinent information on operating limits for the rupture disc. This warrants a benchmark of the vendor manual program and a review of vendor manuals for other rupture discs within the TVA nuclear fleet. This CA was completed prior to the commencement of the

===95001 inspection and verified by inspectors.

ii.

CA 1917980-034: Revise PDM 4.7, "Operations Work Control Interface,"

2, to warn against the possibility of overpressurizing low pressure components during online maintenance, such as closing the HPCI/RCIC steam exhaust isolation valve with potential valve leak by. This CA addresses the second contributing cause. The action mitigates the potential of overpressurizing low pressure system components in the HPCI and RCIC turbine exhaust lines by prompting operators to assess valve lineups with the potential for leak by during work planning. This CA was completed prior to the commencement of the 95001 inspection and verified by inspectors.

4. Objective: Ensure that pending corrective action plans direct prompt and effective actions to

address and preclude repetition of White performance issues.===

Under this objective, the inspectors assessed the appropriateness and timeliness of the licensee's planned corrective actions.

NRC Assessment: The team concluded that this objective was met. The inspectors concluded that the actions designated as CAPRs and CAs are sufficient to address the established root and contributing causes and prevent recurrence.

a.

Planned Corrective Actions to Prevent Recurrence All actions designated as CAPRs were completed prior to commencement of the 95001 inspection.

b.

Other Planned Corrective Actions One interim action (INTR) was complete but implemented with an expiration date which had expired prior to the inspection. The INTR action was recreated with a one-year expiration and a condition report was written with a corrective action to affect permanent implementation into site procedures. Inspectors judged that the INTR action would contribute to the correction of the performance issue.

i.

CA 1991562-001: Incorporate guidance from Operations Standing Order BFN OS-244 into OPDP-8, "Operability Determination Process and LCO Tracking."

This action codifies the standing order guidance in permanent fashion. The standing order directs the documentation of engineering judgment and technical input when operators request engineering assistance in making an immediate determination of operability for structures, systems, and components important to safety. Creating a record of the critical thinking behind an engineering judgment assists in the potential identification of missed requirements such as the operating ratio for the HPCI turbine exhaust line rupture disc.

The inspectors identified two general weaknesses in the licensees actions which are documented in the Results section of this report.

Conclusion The inspectors concluded the corrective actions to preclude repetition of the root and contributing causes (causal factors) of the White performance issue were effective and adequately prioritized considering safety significance and regulatory compliance. In addition, the inspectors determined that evaluations were documented at a sufficient level of detail, included relevant operating experience, and identified the root causes, extent of conditions, and extent-of-causes of the performance issue. Based on the results of the inspections, the inspectors concluded that the objectives of the inspection were met and that the finding will be closed.

INSPECTION RESULTS

Assessment 95001 Temporary Corrective Action Assigned Without a Plan for Permanent Incorporation The licensee assigned an interim action (INTR) in response to the HPCI turbine exhaust rupture disc failure that was completed with an expiration date that had expired at the time of inspection, The INTR action established Operations Standing Order BFN OS-244 which directs the documentation of engineering judgment and technical input when operators request engineering assistance in making an immediate determination of operability for structures, systems, and components important to safety. Creating a record of the critical thinking behind an engineering judgment assists in the potential identification of missed requirements such as the operating ratio for the HPCI turbine exhaust line rupture disc.

Inspectors judged that this INTR action contributes to correcting the root cause identified in the licensee's Level 1 RCE and should be incorporated in a permanent manner. The INTR action was revised with a one-year expiration and CR 1991562 was written with a corrective action to incorporate guidance from BFN OS-244 into OPDP-8 which, following implementation, will address the identified concern. This issue was debriefed with site management and has been referred to the Browns Ferry Resident Inspector staff for future inspection under IP 71152, "Problem Identification and Resolution (PI&R)," to ensure its completion.

Assessment 95001 Repetitive Use of Ineffective Language in the Corrective Action Program Inspectors observed the repetitive use of ineffective language in the corrective action program when creating corrective actions and enhancement actions to address identified conditions adverse to quality and process improvements. Several actions and the initial wording of CR 1991562 used language that would not reasonably accomplish the objective of the action. Examples include "Evaluate putting guidance from BFN OS-244 into OPDP-8..."

and "Determine if a process or expectation needs to be developed..." In these examples, an evaluation or determination can take place that does not result in any action at all. Corrective actions of all categories are most effective when they use directive language to ensure the action takes place. There are multiple examples of ineffective language in the licensee's corrective action program. This issue was debriefed with site management and has been referred to the Browns Ferry Resident Inspector staff for future inspection under IP

EXIT MEETINGS AND DEBRIEFS

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

  • On February 13, 2025, the inspectors presented the 95001 supplemental inspection results to Daniel Komm, Site Vice President, and other members of the licensee staff.

Immediately following the exit meeting, Lou McKown, Chief, Projects Branch 5, conducted the Regulatory Performance Meeting with Daniel Komm and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CR1743531

2-FCV-73-16 was tagged open for PMs and HPCI Exhaust

pressure rose to 160 psig

2/28/2021

CR1991562

Incorporate Guidance from BFN OS-244 into OPDP-8

2/12/2025

Corrective Action

Documents

RCA 1917980

Level 1 Evaluation (RCA) Report

Rev 2

1-47E610-71-1

Mechanical Control Diagram RCIC System

Rev 22

1-47E610-73-1

Mechanical Control Diagram HPCI System

Rev 30

1-47E812-1

Flow Diagram High Pressure Coolant Injection System

Rev 50

1-47E813-1

Flow Diagram Reactor Core Isolation Cooling System

Rev 45

2-47E610-71-1

Mechanical Control Diagram RCIC System

Rev 46

2-47E610-73-1

Mechanical Control Diagram HPCI System

Rev 58

2-47E812-1

Flow Diagram High Pressure Coolant Injection System

Rev 79

2-47E813-1

Flow Diagram Reactor Core Isolation Cooling System

Rev 62

3-47E610-71-1

Mechanical Control Diagram RCIC System

Rev 43

3-47E610-73-1

Mechanical Control Diagram HPCI System

Rev 41

3-47E812-1

Flow Diagram High Pressure Coolant Injection System

Rev 75

3-47E813-1

Flow Diagram Reactor Core Isolation Cooling System

Rev 54

Drawings

D664-19

Drawing Fike Rupture Disc 8in CPV-C 150 ANSI LL

Rev D

BFN-VTM-F103-

0040

Vendor Technical Manual for Fike Rupture Disc Assemblies

Rev 2A

BFN-VTM-F103-

0050

Installation and Maintenance Instructions for Fike Rupture

Disc Assemblies

Rev 5

Miscellaneous

L-2024-005

Laboratory Analysis of Browns Ferry Nuclear Station High

Pressure Coolant Injection (HPCI) Rupture Disc, BWXT

Technologies Inc.

April 2024

1-ARP-9-3B

Alarm Response Procedure

Rev 37

1-ARP-9-3F

Alarm Response Procedure

Rev 31

1-OI-71

Reactor Core Isolation Cooling System

Rev 36

1-OI-73

High Pressure Injection System

Rev 40

2-ARP-9-3B

Alarm Response Procedure

Rev 41

2-ARP-9-3F

Alarm Response Procedure

Rev 44

95001

Procedures

2-OI-71

Reactor Core Isolation Cooling System

Rev 84

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

2-OI-73

High Pressure Injection System

Rev 109

3-ARP-9-3B

Alarm Response Procedure

Rev 27

3-ARP-9-3F

Alarm Response Procedure

Rev 41

3-OI-71

Reactor Core Isolation Cooling System

Rev 76

3-OI-73

High Pressure Injection System

Rev 72

BFN OS-0244

Operations Standing Order

Rev 0

BFN OS-0244

Operations Standing Order

Rev 1

BFN-ODM-4.7

Operations Work Control Interface

Rev 26

NEDP-22

Operability Determinations and Functional Evaluations

Rev 25

NPG-SPP-09.0

Conduct of Engineering

Rev 17

NPG-SPP-22.300

Corrective Action Program

Rev 26

NPG-SPP-22.305

Level 2 Evaluations

Rev 8

NPG-SPP-22.306

Level 1 Evaluations

Rev 8

OPDP-8

Operability Determination Process and Limiting Conditions

for Operation Tracking

Rev 33