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

UNITED STATES 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 Enterprise Identifier: I-2018-012-0017 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 Enclosure

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 Report Section Aspect Mitigating Green NCV 05000296/2018-012-01 None 71153 Systems Closed 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 Status Section LER 05000296/2018-002-00 Inoperable 250V Shutdown Board 71153 Closed Battery Charger Results in Condition Prohibited by Technical Specifications

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

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.

71152Problem Operating Experience, Self-Assessments, and Audits Assessment 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.

71152Problem Safety Conscious Work Environment Assessment 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 Report Aspect Section Mitigating Green NCV 05000296/2018-012-01 None 71153 Systems Closed

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 1221273 1336241 1423322 1384056 1385434 1389480

1146001 1228557 1336242 1423322 1384057 1393879 1414608

1146363 1249802 1336246 1427962 1392134 1409305 1423044

1150455 1298080 1340855 1431238 1407222 1272790 1233079

1169573 1249717 1340872 1433902 1419921 1153853 1294294

1119892 1249723 1346131 1436281 1420973 1166017 1161911

1153826 1253350 1347792 1147778 1336830 1189404 1204735

1157981 1268051 1350086 1157182 1337825 1292179 1159943

1158463 1281537 1352009 1157862 1328204 1353663 1192000

1160702 1286193 1354876 1158643 1337825 1354876 1170978

1168726 1233084 1389131 1165935 1413039 1353667 1131140

1170980 1294760 1393879 1170124 1170978 1354886 1133821

1176706 1303737 1402739 1258736 1189508 1233049 1112692

1176922 1312984 1403761 1266308 1237382 1175751 1170971

1195081 1322394 1413619 1267323 1268177 1186857 1115172

201196 1329543 1413619 1284073 1395402 1229794 1179483

204730 1331462 1413620 1285600 1161179 1252195 1228065

212034 1332866 1413621 1328204 1161926 1336349 1385280

219043 1333906 1413623 1329024 1172128 1374607 1260619

21265 1420413 1379565 1348588 1382275 1413623

1143588 1233076 1158499 1242311 1331793 1228030 868804

1143590 1170968 1163243 1258637 1345723 1241805 1383682

1170970 1179696 1181071 1276753 1145799 1354876

260580 1142006 1189810 1314615 1393423

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 119259118 119531837

117760950 115707718 113729018

117764640 117595795 117217900

117821415 117962593 117877268

117861528 118372021 117638828

117877268 118433481 117675541

118304355 118557418 117692872

118393397 118880286 117770137

119186157 118880287 117822991

119371766 118662022 118014100

119524773 118680184 119408126

119594233 118680351 119539861

119639339 118842853

119639366 119099221

119639704 119259118

119676900 119462580

Cancelled Work Orders (WOs)

117977191 117966837 117952469

117968137 117967265 117910853

117822890 118330690 117648294

117966856 117651167 117663684

119685837 119130053 118456896

119130053 118660656 118225189

118288229 118578729 118169216

117698103 118493283 117724905

118152936 118237511 118027573

118077890 118122113 117938363

117968137 118091807 117907703

117888235 118061119 117907705

117838767 119158148

117839581 119158087

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

10