IR 05000259/2021011

Temporary Instruction 2515/TI-193 Inspection Report 05000259/2021011, 05000260/2021011, and 05000296/2021011

ML21236A028
Person / Time
Site:	Browns Ferry
Issue date:	08/24/2021
From:	Shawn Smith Reactor Projects Region 2 Branch 6
To:	Jim Barstow Tennessee Valley Authority
References
IR 2021011
Download: ML21236A028 (13)

Text

August 24, 2021

Mr. Jim Barstow Vice President, Nuclear Regulatory Affairs and Support Services Tennessee Valley Authority 1101 Market Street, LP 4A-C Chattanooga, TN 37402-2801

SUBJECT: BROWNS FERRY NUCLEAR PLANT - TEMPORARY INSTRUCTION 2515/TI-193 INSPECTION REPORT 05000259/2021011, 05000260/202 1011, AND 05000296/2021011

Dear Mr. Barstow:

On August 6, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Browns Ferry Nuclear Plant. On August 13, 2021, the NRC inspec tors discussed the results of this inspection with Mr. M. Rasmussen and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is document ed in this report. This finding did not involve a violation of NRC requirements.

If you disagree with a cross-cutting aspect assignment or a fin ding not associated with a regulatory requirement in this report, you should provide a res ponse within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555- 0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspect or 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.

Sincerely,

/RA/

Steven P. Smith, Chief Reactor Projects Branch 6 Division of Reactor Projects

Docket Nos. 05000259, 05000260, and 05000296 License Nos. DPR-33, DPR-52, and DPR-68

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000259, 05000260 and 05000296

License Numbers: DPR-33, DPR-52 and DPR-68

Report Numbers: 05000259/2021011, 05000260/2021011 and 0500029 6/2021011

Licensee: TVA

Facility: Browns Ferry Nuclear Plant

Location: Athens, Alabama

Inspection Dates: August 02, 2021 to August 06, 2021

Inspectors: B. Bishop, Senior Project Engineer S. Ninh, Senior Project Engineer

Approved By: Steven P. Smith, Chief Reactor Projects Branch 6 Division of Reactor Projects

Enclosure SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitori ng the licensees performance by conducting a Temporary Instruction 2515/TI-193 I nspection 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

Hardened Containment Vent System Preventative Maintenance not P erformed Within Periodicity Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.5] - Work 2515/193 FIN Management 05000259,05000260,05000296/202101 1-01 Open/Closed The inspectors identified a finding of very low safety signific ance (Green) for the failure to perform the required surveillances within periodicity for the h ardened containment vent system (HCVS). Specifically, HCVS valves are required to be st roked once per operating cycle per TVA final integrated plan, CNL-19-004, Table 3-3, Tes ting and Inspection Requirements. At the time of the inspection, the HCVS valves for each unit had been in service for greater than one cycle on each unit; however, these surveillances had never been performed.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of th e inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise note d. Currently approved IPs with their attached revision histories are located on the public web site 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 inspe ction activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Wa ter Reactor Inspection Program - Operations Phase. The inspectors reviewed selected p rocedures and records, observed activities, and interviewed personnel to assess licens ee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergen cy declared by the President of the United States on the public health risks of the coronavi rus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline insp ections were evaluated to determine if all or a portion of the objectives and requirement s stated in the IP could be performed remotely. If the inspections could be performed remot ely, they were conducted per the applicable IP. In some cases, portions of an IP were comple ted remotely and on site. The inspections documented below met the objectives and requirement s for completion of the IP.

OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNOR MAL

2515/193 - Inspection of the Implementation of EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operat ion under Severe Accident Conditions

Inspection of the Implementation of EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (1 Sample)

Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the reliable hardened containment wetwell vent as described in the plant specific submittals and the associated NRC safety evaluation (ADAMS Accession No. ML19329E319), and deter mined that the licensee was in compliance with NRC Order EA-13-109 Phase 1, R eliable, Severe Accident Capable Wetwell Venting System (ADAMS Accession No. M L13143A321).

The inspectors evaluated licensee implementation of the appropr iate elements of the reliable hardened containment wetwell vent as described in the plant specific submittals and the associated NRC safety evaluation (ADAMS Accession No.

ML19329E319). Specifically, the inspectors evaluated licensee i mplementation of the Hardened Containment Vent System (HCVS) functional requirements, design features, maintenance and testing, quality standards, and progr ammatic requirements as described in Appendix A of TI 2515/193 Revision 1.

The inspectors verified that the licensee satisfactorily:

• Installed the HCVS to meet the performance objectives outlined in Order EA-13-109;

• Installed the HCVS system with the design features specified i n Order EA-13-109;

• Designed the HCVS to meet the quality standards described in O rder EA-13-109;

• Developed and implemented adequate maintenance and testing of HCVS equipment to ensure their availability and capability;

• Developed and issued procedures to safely operate the HCVS usi ng normal power supplies, during Extended Loss of All AC Power (ELAP), an d a postulated severe accident scenario, and integrated the procedu res into existing plant procedures; and

• Trained their staff to assure personnel can proficiently opera te the HCVS.

Based on samples selected for review, the inspectors verified t hat the licensee satisfactorily implemented appropriate elements of the reliable wetwell venting strategy as described in the plant specific submittals and the associated safety evaluation (ADAMS Accession No. ML19329E319) and determined tha t the licensee was in compliance with NRC Order EA-13-109 Phase 2, Reliable, Severe Accident Capable Drywell (or alternative st rategy) Venting System (ADAMS Accession No.

ML13143A321).

The inspectors evaluated licensee implementation of the appropr iate elements of the reliable wetwell venting strategy as described in the plant spe cific submittal(s) and the associated NRC safety evaluation (ADAMS Accession No. ML19329E319).

Specifically, the inspectors evaluated licensee implementation of Severe Accident Water Addition / Severe Accident Water Management (SAWA/SAWM) functional requirements, installed instrumentation, maintenance and testin g, and programmatic requirements as described in Appendix B of TI 2515/193 Revision 1.

The inspectors verified that the licensee satisfactorily develo ped a strategy making it unlikely that venting from the containment drywell would be nec essary. As part of that strategy, the licensee:

• Implemented the Severe Accident Water Addition (SAWA)/Severe A ccident Water Management (SAWM) systems as defined and fulfilled functi onal requirements for installed and portable equipment.

• Installed and/or identified the previously-installed instrumen tation necessary to implement SAWM;

• Developed and implemented adequate maintenance and testing of SAWA/SAWM equipment to ensure availability and capability;

• Developed and issued procedures to safely operate the SAWA/SAW M during an ELAP and during postulated severe accident scenario, and int egrated their procedures into their existing plant procedures such that entry into and exiting from the procedures are clear when using existing plant procedu res; and

• Trained their staff to assure personnel can proficiently opera te the HCVS during ELAP and accident scenarios.

INSPECTION RESULTS

Hardened Containment Vent System Preventative Maintenance not P erformed Within Periodicity Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.5] - Work 2515/193 FIN Management 05000259,05000260,05000296/20210 11-01 Open/Closed The inspectors identified a finding of very low safety signific ance (Green) for the failure to perform the required surveillances within periodicity for the h ardened containment vent system (HCVS). Specifically, HCVS valves are required to be st roked once per operating cycle per TVA final integrated plan, CNL-19-004, Table 3-3, Tes ting and Inspection Requirements. At the time of the inspection, the HCVS valves for each unit had been in service for greater than one cycle on each unit; however, these surveillances had never been performed.

Description: Order EA-13-109, Attachment 2, Section 1.2.13 req uires that the HCVS include features and provisions for the operation, testing, inspection, and maintenance adequate to ensure that reliable function and capability are maintained. Re levant guidance is found in NEI 13-02 Sections 5.4 and 6.2; and HCVS-FAQs-05 and -06. TVAs Fin al Integrated Plan, CNL-19-004, Table 3-3, (Testing and Inspection Requirements) define s the surveillance requirements for the HCVS system.

Browns Ferry Hardened Containment Vent System PMs 137277,137278, 137279, 137280, 138726, 149220, 149222, 149223 were not completed within period icity. Under the testing requirements of DCNs 71389, 71390, and 71391, cycling of the HC VS valves and the interfacing system boundary valves not used to maintain contain ment integrity during operations must be cycled once every operating period. After 2 successful performances the test frequency may then be reduced to a maximum of once every other operating cycle. The compliance dates which signal the start of the frequency clock are Unit 1, Nov 2018 ( 1R12),

Unit 3, March 2018 (3R18) and Unit 2, April 2019 (2R20). These frequency due dates have been surpassed by one operating period for each unit. (CR171213 9). At the time of the inspection, the HCVS valves for each unit had been in service f or greater than one cycle on each unit, however, these surveillances had never been performe d.

There were missed opportunities to identify and correct this is sue based on related deficiencies identified by TVA. See bulleted examples below.

• A TVA Self-Assessment for NRC Order EA 13-109 conducted in 2019 noted that PMs required to be performed in accordance with NEI 13-02 had not b een created for all HCVS and SAWA components. (CR 1548744).

• Inspectors noted that Browns Ferry had identified in 20 18 that PMs for HCVS batteries were not in periodicity (CR 1396691)

Corrective Action References: CR 1396691, CR 1548744, CR 17121 39 Performance Assessment:

Performance Deficiency: Failure to comply with TVAs Final Int egrated Plan, CNL-19-004, Table 3-3, Test and Inspection Requirements, was a performance deficiency. The self-imposed surveillance requirements for Browns Ferry Hardened Con tainment Vent System, PMs 137277,137278, 137279, 137280, 138726, 149220, 149222, 1492 23, were not completed within periodicity. Under the testing requirements of DCNs 71389, 71390, and 71391, cycling of the HCVS valves and the interfacing system bo undary valves not used to maintain containment integrity during operations must be cycled once every operating period. The compliance dates which signal the start of the freq uency clock are Unit 1, Nov 2018 ( 1R12), Unit 3, March 2018 (3R18) and Unit 2, April 2019 (2R20). These frequency due dates have been surpassed by one operating period for each unit. (CR1712139).

Screening: The inspectors determined the performance deficienc y was more than minor because it was associated with the SSC and Barrier Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone ob jective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors consulted Exhibit 3, Barrier Integrity, screening questions, Section C, R eactor Containment. The finding screened as Green, or of very low safety significance.

Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and mana gement of risk commensurate to the work and the need for coordination with different groups or job activities.

Enforcement: Inspectors did not identify a violation of regulatory requireme nts associated with this finding.

EXIT MEETINGS AND DEBRIEFS

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

• On August 13, 2021, the inspectors presented the Final NRC ins pection results to Mr. M.

Rasmussen and other members of the licensee staff.

• On August 6, 2021, the inspectors conducted an Onsite Exit Mee ting to communicate preliminary inspection results to Mr. Rasmussen and other membe rs of the licensee staff.

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