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05000259/FIN-2018010-012018Q2Browns FerryLicensee-Identified ViolationThe Browns Ferry Nuclear Plant, Unit 3, Renewed Facility Operating License, DPR-68, License condition 2.C(7) required, in part, that TVA Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c)... Specifically, 10 CFR 50.48(c)incorporated by reference National Fire Protection Association Standard 805 (NFPA 805), and NFPA 805 section 2.4.2.2.2, Other Required Circuits, required in part, Other circuits that share common power supply and/or common enclosure with circuits required to achieve nuclear safety performance criteria shall be evaluated for their impact on the ability to achieve nuclear safety performance criteria. (a) Common Power Supply Circuits. Those circuits whose fire induced failure could cause the loss of a power supply required to achieve the nuclear safety performance criteria shall be identified. This situation could occur if the upstream protection device (i.e., breaker or fuse) is not properly coordinated with the downstream protection device. Contrary to the above, since June 22, 2016, when the NFPA 805 requirements went into effect, the licensee did not implement and maintain in effect all provisions of the approved fire protection program, because the licensee did not correctly evaluate circuits that share common power supply for their impact on their ability to achieve nuclear safety performance criteria in accordance with NFPA 805.Significance: The team evaluated the finding in accordance with NRC Inspection Manual Chapter (IMC) 0609, Attachment 4, Initial Characterization of Findings, issued October 7, 2016, for Mitigating Systems, and IMC 0609, Appendix F, Fire Protection Significance Determination Process, issued May 2, 2018, and determined the finding to be of very low
05000395/FIN-2017007-012017Q4SummerFailure to Verify the Adequacy of Design for the EFW system when Supplied by SWThe NRC identified a non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to verify the emergency feedwater (EFW) pumps would be capable of taking suction from service water for an indefinite period of time as required by Updated Final Safety Analysis Report Section 10.4.9.2. The licensee entered this issue into their corrective action program (CAP) as condition report (CR) 17-05528 and performed an operability determination to verify the EFW pumps remained operable. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to evaluate worst-case design conditions resulted in a reasonable doubt that the EFW pumps could provide cooling water to the steam generators and perform their design basis function. The team determined the finding to be of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of a mitigating structure, system, and component (SSC), and the SSC maintained its operability. The team determined that no crosscutting aspect was applicable because the finding did not reflect current licensee performance
05000395/FIN-2017007-022017Q4SummerFailure to Establish a Testing Program for Inverter XIT5904 and Time Delay Relay in the EFW/SW Crosstie Valve Actuation CircuitryThe NRC identified an NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, involving two examples. Specifically, the licensee (1) failed to establish a testing program to assure the adequacy of the shutdown setpoint of the safety-related inverters, and (2) failed to establish a testing program to assure the adequacy of the time delay relay in the emergency feedwater/service water (EFW/SW) crosstie valve actuation circuitry. The licensee entered this issue into their CAP as CRs17-05534 and 17-05536, and performed an operability determination to verify that the safety-related components remained operable. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failing to establish a testing program for the low voltage DC setpoint of inverter XIT 5904 and for the time delay relay in the EFW/SW crosstie actuation circuitry could result in undetected degradation of the equipment to perform their intended safety functions. The team determined the finding to be of very low safety significance (Green) because it was a deficiency affecting the design or qualification of a mitigating SSC, and the SSC maintained its operability. The team determined that no cross-cutting aspect was applicable because the finding did not reflect current licensee performance.
05000395/FIN-2017007-032017Q4SummerFailure to Identify a CAQ for Power Shield Catalog #609903-T501NThe NRC identified an NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, for the licensees failure to identify that a deviation in equipment qualification of power shield relays in 480V switchgear XSW-1DB1 was a condition adverse to quality in their CAP. Specifically, the licensee failed to identify that Power Shield catalog #609903-T501N in purchase order NU-02SR750589 was not qualified to meet its original total integrated dose limit of 100,000 rads as stated in the Asea Brown Boveri 10 CFR Part 21 notification letter. The licensee entered this issue into their CAP as CR-17-05391 and performed an evaluation to determine there was reasonable assurance that the power shield relay in purchase order NU-02SR750589 could perform its intended safety function. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to identify that Power Shield catalog #609903-T501N in purchase order NU-02SR750589 was not qualified to the 1,350 rad TID specified in the equipment qualification database for zone AB-72 resulted in a reasonable doubt that the qualification requirements over the relays service life would be met. The team determined the finding to be of very low safety significance (Green) because the finding affected the design or qualification of a mitigating SSC and the SSC maintained its operability. The team determined that no crosscutting aspect was applicable because the finding did not reflect current licensee performance.
05000395/FIN-2017007-042017Q4SummerLicensee-Identified ViolationTitle 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that design control measures provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. Contrary to the above, since 2010, the licensee failed to evaluate the loading of the emergency diesel generators at the maximum voltage and frequency allowed by TS 3/4.8.1 in Calculation DC08360-006, Diesel Generator 1A and 1B Loading, Rev. 12, and to evaluate battery terminal voltage at the maximum battery cell-to-cell resistance allowed by TS 3/4.8.2 in Calculation DC08320-010, Class 1E 125 Volt DC System Voltages and Voltage Drop, Rev. 18. The team determined the finding to be of very low safety significance (Green) because the finding was a deficiency affecting the design of a mitigating SSC, and the SSC maintained its operability. The licensee entered these issues into their CAP as CRs 10-02395 and 10-02033. ATTACHMENT: SUPPLEMENTAL INFORMATION
05000250/FIN-2017007-102017Q3Turkey PointPotential failure of 125 Vdc Bus 3B Class 1E componentsUFSAR Section 8.2.2.3.1 stated that the emergency power for vital instrumentation and controls is supplied by a station DC power system which contains five safety related 125Vdc batteries and four DC distribution panels. 125 Vdc distribution panel 3B supplies safety related power to several safety-related equipment including sequencers, reactor trip switchgear, inverter 3Y06, and control power to 480Vac load centers 3B and 3D and 4160 Vac switchgears 3AB01 and 4AB20. UFSAR Section 7.2 stated that the reactor protection system was designed in accordance with IEEE 279- 1968. Section 4.5 of IEEE 279-1968, Channel Integrity, requires all protection system channels be designed to maintain necessary functional capability under extremes of conditions relating to malfunctions. During the review of calculation 5177-265-EG-22, Circuit Breaker/Fuse Coordination Study, Rev. 8, the team questioned if there were instances where class 1E cables associated with DC Bus 3B (3D23) would not be adequately protected given a short circuit on the load side of the breakers. The failure to ensure the Class 1E protective devices would not allow the maximum available short circuit to permanently damage cabling to safety-related equipment associated with DC Bus 3B could result in additional loss of Class 1E equipment. Unresolved Item (URI) 05000250/2017007-01 and 05000251/2017007-01, Potential failure of 125 Vdc Bus 3B Class 1E components,) is opened for additional review to determine if the Class 1E cables on DC Bus 3B can withstand the maximum possible short circuit and to determine if a performance deficiency exists.
05000250/FIN-2017007-012017Q3Turkey PointInadequate Verification of Electrical Protective Device Selective CoordinationThe NRC identified a non-cited violation of Title 10 Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for failure to verify that coordination exists between the protective devices on safety related switchgear in order to minimize the probability of losing a safety related power bus. For immediate corrective actions, the licensee entered this issue into their corrective action program as Action Request (AR) 2220956 and performed an operability determination, which determined the system was operable, and was performing a reevaluation of the calculation to determine adequate coordination. The performance deficiency was determined to be more than minor because it was associated with the Design Control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failing to verify short circuits in non-safety related SSCs downstream of the safety related switchgear would not cause a lockout of the safety related bus affected its availability and reliability. The team determined the finding to be of very low safety significance because the finding was a deficiency affecting the design of a mitigating structure, system, or component (SSC), and the SSC maintained their operability or functionality. This finding was not assigned a cross-cutting aspect because the issue did not reflect current licensee performance.
05000250/FIN-2017007-022017Q3Turkey PointFailure to Perform Design Verification for Under Frequency Trip of the Main Generator BreakersThe NRC identified a non-cited violation of Title 10 Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for failure to verify or check the adequacy of design of the under frequency trip feature of the main generator circuit breakers with regard to the effect of its operation on plant stability and the maintenance of critical safety functions. The licensee entered this issue into their corrective action program as AR 2220874 and AR 2224998. The performance deficiency was determined to be more than minor because it was associated with the Design Control attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions. Specifically, opening of the main generator breakers due to an under frequency condition on the offsite power system would cause the generator load to suddenly drop from full power to the level of the plant loads, and there was no verification that plant stability and critical safety functions would be maintained. The team evaluated the finding with Inspection Manual Chapter 0609, Appendix A, and determined the finding met the Support System Initiators screening criteria for requiring a detailed risk evaluation. The team determined that this issue increased the likelihood of the support system initiator loss of offsite power (LOOP). The regional senior risk analyst conducted a detailed risk evaluation with a one year exposure and determined the change in core damage frequency was less than 1E-6, which was of very low safety significance (Green). The team did not assign a cross-cutting aspect because the issue did not reflect current licensee performance.
05000250/FIN-2017007-032017Q3Turkey PointFailure to Verify the Adequacy of CCW isolation from Supplemental Cooling System (SCS)The NRC identified a non-cited violation of Title 10 Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to verify the adequacy of design of temperature set points used for isolation of the Component Cooling Water (CCW) from the CCW supplemental cooling system (SCS) during an accident. For immediate corrective actions, the licensee entered this into their corrective action program as AR 2218834, performed an operability determination, which determined the system is operable but non-conforming, and issued engineering change (EC) 289598 to account for uncertainties in the CCW SCS temperature isolation setpoint. The performance deficiency was determined to be more than minor because it was associated with the Design Control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and 4 capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, by not ensuring prompt isolation or adjusting the isolation setpoint to account for instrument uncertainties and temperature lag, the licensee failed to ensure that the SCS loop would be isolated at onset of an accident, which affected the reliability and capability of the CCW system when called upon. The determined the finding to be of very low safety significance because the findings were a deficiency affecting the design of a mitigating structure, system, or component (SSC), and the SSC maintained their operability or functionality. The finding had a cross-cutting aspect in the area of Human Performance because the licensee failed to ensure knowledge transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values (H.9).
05000250/FIN-2017007-042017Q3Turkey PointFailure to Verify the Adequacy of Design for Component Protective CoversThe NRC identified a Green non-cited violation of Title 10 Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to verify the adequacy of design for the non-safety related component protective covers attached to safety related equipment. For immediate corrective actions, the licensee entered this into their corrective action program as AR 02220993 and removed visibly degraded protective covers. 3 The performance deficiency was determined to be more than minor because it was associated with the Design Control attribute and of the Initiating Events Cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as pow er operations. Specifically, the failure to ensure the quality and qualification of commercial components and assemblies to maintain adequate mounting to Class 1E equipment increased the likelihood of inadvertent component failures, and thus increased the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The team determined the finding to be of very low safety significance because the finding did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition (e.g. loss of condenser, loss of feedwater). This finding was not assigned a cross-cutting aspect because the issue did not reflect current licensee performance.
05000250/FIN-2017007-052017Q3Turkey PointFailure to Adequately Perform Discharge Testing on Battery 3BThe NRC identified a non-cited violation of Title 10 Code of Federal Regulations Part 50, Appendix B, Criterion XI, Test Control, for the licensees failure to perform surveillance testing on station battery 3B in accordance with the requirements of Institute of Electrical and Electronic Engineers (IEEE) 450-1987. For immediate corrective actions, the licensee entered this issue into their corrective action program as AR 2219948 and performed an extent of condition review, which determined that none of the station batteries were currently in a degraded condition, and placed surveillance procedure 0-SME-003.15 on administrative hold until the corrective actions are completed. The performance deficiency was determined to be more than minor because if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern. Specifically, the performance deficiency could result in masking degradation of the battery on future performance discharge tests and adversely affect the ability to trend when the testing periodicity should be increased to once a year as required by Technical Specifications (TS). The team determined the finding to be of very low safety significance because the finding did not represent an actual loss of function of one or more non-TS trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hrs. This finding was not assigned a cross-cutting aspect because the issue did not reflect current licensee performance.
05000250/FIN-2017007-062017Q3Turkey PointFailure to Verify the Adequacy of Design for the ECC and CCW SystemsThe NRC identified a non-cited violation of Title 10 Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to verify the Emergency Containment Cooler (ECC) unit 4A auto start circuitry would not result in exceeding the thermal limits of the CCW system during a design basis accident. Specifically, the licensee failed to verify that a single active failure of the motor starter auxiliary contacts would not result in exceeding the design basis limits for CCW as described in updated final safety analysis report (UFSAR) Section 9.3. For immediate corrective actions, the licensee entered the issue into their corrective action program as AR 2219505, performed a prompt determination of operability, and determined that the CCW system remained operable. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, three ECC fans running during a during a design basis accident would result in exceeding the design basis temperature of 158.6 F for the 5 CCW supply and a significant reduction in margin for the SI pump lube oil cooler. The team determined the finding to be of very low safety significance because the finding was a deficiency affecting the design of a mitigating structure, system, or component (SSC) and the SSC maintained its operability. This finding was not assigned a cross- cutting aspect because the issue did not reflect current licensee performance.
05000250/FIN-2017007-072017Q3Turkey PointFailure to Identify ICW Pipe CorrosionThe NRC identified a non-cited violation of Title 10 Code of Federal Regulations Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to inspect Intake Cooling Water (ICW) piping in accordance with license renewal commitments. For immediate corrective actions, the licensee entered the issue into their corrective action program as AR 02218430 and AR 02218437, planned to perform localized corrosion wall thickness measurements to ensure the ICW system remained operable. The performance deficiency was determined to be more-than-minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, unmonitored corrosion affects the reliability of the ICW systems. The team determined the finding to be of very low safety significance because it did not represent an actual loss of function of one or more non-Tech Spec trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for >24 hrs. The finding had a cross-cutting aspect in the area of Problem Identification and Resolution, Identification, because the licensee failed to implement a corrective action program with a low enough threshold for identifying issues (P.1). Specifically, individuals routinely failed to identify corrosion issues on CCW system area walk downs that exceeded proceduralized acceptance criteria of light surface rust specified in 0-ADM- 564, during the July 5, 2017, August 11, 2016, and April 11, 2016 CCW area walk downs.
05000250/FIN-2017007-082017Q3Turkey PointFailure to Correct a Non-Conforming Condition Impacting ContainmentThe NRC identified a non-cited violation of Title 10 Code of Federal Regulations Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to take timely corrective action to maintain the unit 3 and 4 containment cathodic protection systems. These systems have been non-functional on both units since 2009. The cathodic protection systems purpose is to protect the containments interconnected liner, reinforcing bars, and tendon trumplates. For immediate corrective actions, the licensee entered the issue into their corrective action program as AR 2216534 and performed a prompt operability determination. The licensee concluded that the containment structure was operable but non-conforming and established plans to monitor the potentially impacted inaccessible areas through continued performance of the American Society of Mechanical Engineers (ASME) IWL and IWE programs until actions are taken to restore the Cathodic Protection System. The performance deficiency was determined to be more than minor, because it is associated with the Design Control attribute of the Barrier Integrity cornerstone and affected the cornerstone objective of maintaining the containment structural integrity and operational capability to provide reasonable assurance that the containment protects the public from radionuclide releases caused by accident or events. Specifically, the failure 6 to implement timely corrective actions to maintain the protection of the containments interconnected liner, reinforcing bars, and tendon trumplates affected the structural integrity and operational capability of the containment structure. The team determined the finding to be of very low safety significance because the finding was not a pressurized thermal shock issue, did not represent an actual open pathway in the physical integrity of the reactor containment, and did not involve an actual reduction in function of hydrogen igniters in the reactor containment. This finding was not assigned a cross-cutting aspect because the issue did not reflect current licensee performance
05000250/FIN-2017007-092017Q3Turkey PointFailure to Update the UFSAR with the Latest Information DevelopedThe NRC identified a Severity Level-IV non-cited violation of Title 10 Code of Federal Regulations 71(e), Maintenance of Records, Making of Reports, for the failure to assure that the Updated Final Safety Analysis Report (UFSAR) contained the latest information developed, including all changes made in the facility or procedures as described in the UFSAR. The team determined that the licensee failed to update the UFSAR to include the latest information regarding several design features associated with turbine runback. For immediate corrective actions, the licensee entered this issue into their corrective action program as AR 2218695 to update the UFSAR. The NRC determined this violation was associated with a minor performance deficiency in accordance with the screening criteria in IMC 0612, Appendix E. Because the failure to update the UFSAR impacted the NRCs ability to perform its regulatory process, the team evaluated the violation using the traditional enforcement process. The team determined that this met the criteria for a SLIV violation because not accurately describing turbine runback design features in the UFSAR could have a material impact on licensed activities, and met the SLIV violation criteria in 6.1.d.3 of the NRC Enforcement Policy. The violation represented a failure to update the UFSAR as required by Title 10 Code of Federal Regulations Part 50.71(e), but the lack of up-to- date information has not resulted in any unacceptable change to the facility or procedures. Cross-cutting aspects are not assigned to traditional enforcement violations