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05000296/FIN-2018003-0130 September 2018 23:59:59Browns FerrySelf-revealingMain Steam Relief Valves Lift Settings Outside of Technical Specifications Required SetpointsA self-revealed SL IV NCV of Technical Specification (TS) 3.4.3, Safety Relief Valves, was identified when the licensee discovered, through as found test results, that three of the thirteen main steam relief valves (MSRVs) that were removed during the Spring 2018 Unit 3 outage had as found lift settings outside of the +/- 3 percent band required for their operability. The LER was associated with three of the thirteen MSRVs as found setpoints being outside of the +/- 3 percent setpoint band required for their operability. This was discovered on May 17, 2018, following as-found testing results conducted on all thirteen MSRVs that were removed during the refueling outage. The licensee determined that the three MSRV pilot discs had corrosion bonding to their valve seats as a result of their platinum anti-corrosion coatings flaking off. The licensee determined that these three MSRVs were inoperable for an indeterminate period of time from March 26, 2016, when the unit entered Mode 2 (beginning of operating cycle) to February 17, 2018, when the unit entered Mode 4 (beginning of refueling outage). The inspectors reviewed the licensee event report and determined that the report adequately documented the summary of the event including the cause and potential safety consequences. The inspectors also reviewed other documents that indicate that this type of failure is a known industry issue associated with this type of valve.
05000296/FIN-2018002-0230 June 2018 23:59:59Browns FerryNRC identifiedInoperable Residual Heat Removal (RHR) Pump Results in Condition Prohibited by Technical SpecificationsA self-revealed SL IV NCV of TS 3.5.1 and 3.6.2.3 was identified when the licensee discovered that the 3A RHR pump was inoperable for longer than the allowed outage time and follow on action completion time.
05000260/FIN-2016002-0330 June 2016 23:59:59Browns FerryNRC identifiedFailure to Report a Condition that Could Have Prevented Fulfillment of a Safety FunctionAn NRC identified Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) 50.72(b)(3)(v) and 10 CFR 50.73(a)(2)(v) was identified for the licensee's failure to notify the NRC within 8 hours and submit an LER within 60 days of discovery of a condition that could have prevented the fulfillment of a safety function. Specifically, the licensee failed to notify the NRC that the High Pressure Coolant Injection (HPCI) system had been rendered inoperable due to an equipment failure. As an immediate corrective action, the licensee entered the violation into the licensee's corrective action program as CR 1185268. The licensees failure to provide the required notification constitutes a traditional enforcement violation because it impacts the NRC's ability to carry out its regulatory function. The traditional enforcement violation was determined to be Severity Level IV because it matched example 6.9.d.9 of the NRC Enforcement Policy. Because the violation is a traditional enforcement violation, no cross-cutting aspect was assigned.
05000259/FIN-2015001-0531 March 2015 23:59:59Browns FerryNRC identifiedFailure to Update FSARAn NRC identified non-cited violation (NCV) of 10 CFR 50.71(e)(4) was identified for the licensees failure to reflect all changes made in the facility or procedures as described in the Final Safety Analysis Report (FSAR) up to a maximum of six months prior to the date of filing the periodic updates to the FSAR with the NRC. The licensees immediate corrective action was to enter this issue into their CAP as PER 1008424 to update areas in the FSAR identified by the NRC. The inspectors determined that traditional enforcement per NRC Enforcement Policy was applicable since this finding reflects an impact on the regulatory process in the form of timely and accurate reports to the NRC. Section 6.1.d.3 of the enforcement policy states, in part, that a failure to update the FSAR as required by 10 CFR 50.71(e) in cases where the information is not used to make an unacceptable change to the facility or procedures is a SL IV violation. The inspectors did not identify any occurrence where the lack of timely updates to the UFSAR resulted in an unacceptable change to the facility or procedures. Crosscutting aspects are not assigned for traditional enforcement violations.
05000296/FIN-2015001-0631 March 2015 23:59:59Browns FerryNRC identifiedFailure to Report Condition Prohibited by TSAn NRC identified non-cited violation (NCV) of 10 CFR 50.73(a)(2)(i)(B) was identified for the licensee's failure to report, within 60 days of discovery, a condition which was prohibited by the plants Technical Specifications (TS). Specifically, the licensee failed to notify the NRC that in two instances a traversing incore probe (TIP) primary containment isolation valve (PCIV) was inoperable for a duration that exceeded the Technical Specification (TS) Completion Time. As an immediate corrective action, the licensee entered the issue into its CAP as PER 1008300 and plans to submit an LER. The licensees failure to provide a written event report is a traditional enforcement violation because it impacts the NRC's ability to carry out its regulatory function. The traditional enforcement violation was determined to be Severity Level IV because it matched example 6.9.d.9 of the NRC Enforcement Policy. Because the violation is a traditional enforcement violation, no cross-cutting aspect was assigned.
05000259/FIN-2014005-0331 December 2014 23:59:59Browns FerryLicensee-identifiedLicensee-Identified ViolationThe following Severity Level IV violation was identified by the licensee and is a violation of NRC requirements which meet the criteria of the NRC Enforcement Policy, for being dispositioned as a Non-Cited Violation. On October 4, 2014, 1B and 1D Outboard MSIVs leak rate test results were found to b above allowed limits at 114.7 and 158.7 standard cubic feet per hour (scfh). Technical Specification 3.6.1.3 D, Primary Containment Isolation Valves (PCIVs), requires, in part, that MSIV leakage meet the leak rate limit of 100 scfh to be operable in Modes 1, 2, and 3. Technical Specification 3.6.1.3, Required Action D.1, requires that when MSIV leak rates are not met that they be restored within 4 hours or be in Mode 3 within 12 hours and Mode 4 within 36 hours. Contrary to the above, since the last successful leak rate test on October 21, 2012, the 1B and 1D Outboard MSIVs became inoperable an action was not taken to restore the leakage rate within limits. The Inboard valves leak rate was sufficiently low to maintain the pathway isolation function. This violation was identified by the licensee and entered in the licensees corrective action program as PER 940890. Traditional enforcement was applicable because no performance deficiency was identified in association with this violation. The licensee had not had sufficient time to perform planned corrective actions developed from previous vendor improvement recommendations. Per the NRC Enforcement Policy section 6.1(d)1 this was determined to be a Severity Level IV violation.
05000259/FIN-2014004-0230 September 2014 23:59:59Browns FerryNRC identifiedInappropriate Amendment of License ConditionsThe NRC identified a Severity Level IV (SL-IV) NCV of 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, and an associated Green NCV of Technical Specification (TS) 3.8.7 Distribution System Operating for the licensees failure to obtain a license amendment prior to implementing changes to the Technical Requirements Manual (TRM) that affected TS 3.8.7 for Units 1, 2, and 3. Specifically, the addition of TRM 3.7.6, Electric Board Room (EBR) Air Conditioning (AC) system resulted in a violation of T.S. 3.8.7 Distribution- Operating for the C and D 4kV shutdown boards (supported by the Unit 2 EBR AC system) being inoperable in mode 1 for longer than the allowed outage time and the action statement not complied with. The licensees immediate corrective action was to issue administrative guidance to operators for the determination of operability of the 4kV shutdown boards with the Electric Board Room air conditioning system inoperable and initiate actions to submit a TS amendment request as documented in PER 846040. The performance deficiency was more than minor because it adversely affected the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the performance deficiency resulted in the licensee not declaring Unit 1 and 2 4kV shutdown boards inoperable and taking actions required by TS 3.8.7 action statement E on multiple occasions. The finding was screened using IMC 0609 Appendix A Exhibit 2, dated June 19, 2012, and was determined to be of very low safety significance (Green) because the finding did not represent an actual loss of function of one or more non-Tech Spec Trains of equipment designated as high safetysignificant in accordance with the licensees maintenance rule program for >24 hrs. The violation was determined to be a Severity Level IV violation using the Enforcement Policy example 6.1.d.2, because it resulted in a condition having a very low safety significance. No cross cutting aspect was assigned in association with the ROP finding because the change to the TRM was performed greater than three years ago and did not reflect current licensee performance.
05000260/FIN-2013005-0631 December 2013 23:59:59Browns FerryNRC identifiedFailure to report a condition prohibited by Technical SpecificationsThe NRC identified a non-cited violation (NVC) of 10 CFR 50.73(a)(2)(i)(B) for the licensees failure to submit a License Event Report (LER) for a condition prohibited by plant technical specifications within 60 days of the event. The licensee entered this issue into their corrective action program as Problem Event Report 796578. LER 50-259 2013-006-00 was submitted on December 4, 2013. The failure to make reports to the NRC as required by 10 CFR 50.73(a)(2)(i)(B) impacted the regulatory process and was a violation of NRC requirements. The violation was processed using traditional enforcement and determined to be a Severity Level IV violation consistent with NRCs Enforcement Policy section 6.9.d.9, Inaccurate and Incomplete Information or Failure to Make a Required Report. Because this violation involved the traditional enforcement process with no underlying technical violation that would be considered more than minor in accordance with IMC 0612, a cross-cutting aspect was not assigned to this violation.
05000259/FIN-2013010-0231 December 2013 23:59:59Browns FerryNRC identifiedInadequate Evaluation of Combustible Material Control Fire Protection Program ChangeThe inspectors identified a Severity Level IV, non-cited violation (NCV) of Browns Ferry Nuclear Plant (BFN) Renewed Facility Operating License Conditions 2.C.(13), (14), and (7) for Units 1, 2, and 3, respectively, and an associated finding of very low safety significance (Green) for the failure to perform an evaluation of the impact of a change to the Fire Protection Report on the fire protection license conditions, as directed by the licensees procedure, FPDP-3, Management of the Fire Protection Report, Revision 3. The failure to adequately evaluate the impact of the change, which permitted the use of fire retardant treated wood materials as transient fire loads in safety related plant areas without further approval, resulted in the implementation of a change to the Fire Protection Program (FPP) that could have adversely affected the ability to achieve and maintain safe shutdown. The licensee also failed to submit the FPP change to the NRC for review and approval prior to implementation which impacted the ability of the NRC to perform its regulatory oversight function. The licensee entered the issue into their corrective action program (CAP) as problem evaluation report PER 812091 and issued an operations Fire Protection Section Instruction Letter to require all wood products to be evaluated when left unattended in any plant fire area. The inspectors determined that this finding was more than minor because if left uncorrected, could become a more significant safety concern. Specifically, if the licensee does not limit transient fire loads (including fire retardant treated wood) to below the capability of suppression systems or fire barrier ratings for a specific fire area as evaluated by the stations fire hazard analysis, a fire could spread to other fire areas and affect the ability to achieve and maintain safe shutdown in the event of a fire. The finding was evaluated using IMC 0609, Attachment 4, Initial Characterization of Findings, issued June 19, 2012, for Mitigating Systems, and IMC 0609, Appendix F, Fire Protection Significance Determination Process, issued September 20, 2013, and the inspectors determined the finding was of very low safety significance (Green) because the reactor would have been able to reach and maintain safe shutdown conditions under actual fire loading conditions. The SDP, however, does not specifically consider the regulatory process impact. Thus, although not related to a common regulatory concern, it is necessary to address the violation and finding using different processes to correctly reflect both the regulatory importance of the violation and the safety significance of the associated finding. The traditional enforcement violation was evaluated using the NRC Enforcement Policy, dated January 28, 2013, revised July 9, 2013, and the inspectors determined the violation was SL-IV per Section 6.1.d.2 of the Enforcement Policy, because the associated finding was evaluated by the SDP as having very low safety significance (i.e., Green). The inspectors determined failure to obtain prior NRC approval for fire protection program changes was similar to violations of 10 CFR 50.59 for enforcement purposes. No cross-cutting aspect was assigned to this finding because the cause of the finding was not indicative of present licensee performance, since the change to the Fire Protection Report occurred in 2003.
05000259/FIN-2013405-0130 June 2013 23:59:59Browns FerryNRC identifiedSecurity
05000259/FIN-2012002-0431 March 2012 23:59:59Browns FerryNRC identifiedRepeated Failure to Report ECCS Analyses Methodology Change or ErrorsDuring discussions between the NRC staff, the fuel vendor, and the licensee starting in April 2010, the NRC staff questioned the appropriateness of the application of credit for spray cooling in the Units 2 and 3 ECCS evaluation, and the effect non-single failure proof ADS would have on the ECCS evaluation model for the BFN units. In a letter dated April 30, 2010 the licensee acknowledged the single failure issue with ADS and indicated that the estimated effect of the change or error on peak clad temperature (PCT) was not significant (greater than 50 degrees Fahrenheit). TVA committed to modify the ADS to provide a single failure proof automatic initiation capability of 4 ADS valves. The licensee also outlined the compensatory measures intended to address the identified degraded/nonconforming condition. Subsequently, on June 30, 2011, TVA submitted the annual ECCS evaluation model report and indicated a minor change to the radiative heat transfer model which resulted in a minor change in PCT for Units 2 and 3. On October 7, 2011, TVA submitted a revised ECCS analysis in support of a Unit 1 fuel transition request. This analysis provided a methodology change to address the evaluation model error associated with spray cooling, which had been identified by the NRC staff, and for which the licensee implemented operating restrictions to ensure that the effects of the error would not cause the predicted PCTs at Units 2 and 3 to exceed 2200F.. This analysis was also applicable for current operating conditions for Units 2 and 3 and was not previously reported to the NRC. NRC review identified that the effect of the evaluation model error would have resulted in greater than a 50 degree increase in predicted PCT for Units 2 and 3. On February 29, 2012, TVA initiated Service Request 514121 which recognized that a 30-day report for a significant change in peak clad temperature consistent with 10 CFR 50.46 had not been submitted. As of March 30, 2012, TVA had not submitted the required 30-day report for a significant change in peak clad temperature consistent with 10 CFR 50.46 which was identified on February 29, 2012. Following the end of the reporting period, TVA submitted the required report per 10 CFR 50.46 on April 18, 2012. Analysis: The inspectors determined that the licensees repeated failure to report changes or errors in the ECCS analyses was a performance deficiency. The inspectors reviewed this issue in accordance with IMC 0612, Appendix B, and determined the performance deficiency did not constitute a Finding, but the failure to report impacted the regulatory process and was subject to traditional enforcement consistent with the discussion for Block 7, Figure 2, Paragraph 2.a.v. The violation was determined to be more than minor per the NRC Enforcement Manual, Section 2.10.F, since the NRC has evidence that this failure to report has occurred repeatedly. This violation was determined to be a Severity Level IV violation based on section 6.9 of the NRC Enforcement Policy. Enforcement: 10 CFR 50.46 (a)(3)(ii), requires for each change to or error discovered in an acceptable evaluation model or in the application of such a model that affects the temperature calculation, the licensee shall report the nature of the change or error and its estimated effect on the limiting ECCS analysis to the Commission at least annually. If the change or error is significant, the applicant or licensee shall provide this report within 30 days and include with the report a proposed schedule for providing a reanalysis or taking other action as may be needed to show compliance with 10 CFR 50.46 requirements. Contrary to the above, the licensee failed to report each change or error discovered in an acceptable evaluation model or in the application of such a model that affects the temperature calculation for Units 2 and 3. Specifically, from May 29, 2011 to April 18, 2012, the licensee failed to report a significant change in peak clad temperature associated with an error related to spray cooling to the NRC within 30 days, and include with the report a proposed schedule for providing reanalysis or taking other action as may be needed to show compliance. The licensee subsequently submitted the required report per 10 CFR 50.46. Because this violation was determined to be a Severity Level IV violation and was entered into the licensees CAP as PER 531752, this violation is being treated as an NCV consistent with the Enforcement Policy. This NCV is identified as NCV 05000260(296)/2012002-04, Repeated Failure to Report ECCS Analyses Methodology Change or Errors.
05000259/FIN-2011005-0131 December 2011 23:59:59Browns FerryNRC identifiedFailure to Report a Valve Motor Operator Manufacturing Defect Pursuant to 10CFR21.21 in a Timely MannerThe inspectors reviewed the two specific structures, systems and components (SSC) within the scope of the Maintenance Rule (MR) (10CFR50.65) with regard to some or all of the following attributes, as applicable: (1) Appropriate work practices; (2) Identifying and addressing common cause failures; (3) Scoping in accordance with 10 CFR 50.65(b) of the MR; (4) Characterizing reliability issues for performance monitoring; (5) Tracking unavailability for performance monitoring; (6) Balancing reliability and unavailability; (7) Trending key parameters for condition monitoring; (8) System classification and reclassification in accordance with 10 CFR 50.65(a)(1) or (a)(2); (9) Appropriateness of performance criteria in accordance with 10 CFR 50.65(a)(2); and (10) Appropriateness and adequacy of 10 CFR 50.65 (a)(1) goals, monitoring and corrective actions (i.e., Ten Point Plan). The inspectors also compared the licensees performance against site procedure NPG-SPP-3.4, Maintenance Rule Performance Indicator Monitoring, Trending and Reporting; Technical Instruction 0-TI-346, Maintenance Rule Performance Indicator Monitoring, Trending and Reporting; and NPG SPP 3.1, Corrective Action Program. The inspectors also reviewed, as applicable, work orders, surveillance records, PERs, system health reports, engineering evaluations, and MR expert panel minutes; and attended MR expert panel meetings to verify that regulatory and procedural requirements were met. FnResidual Heat Removal Service Water (RHRSW) 023-C, Vessel / Containment Flooding MR Function Reclassified as Risk Significant FnUnit 1, Loop I RHR Low Pressure Coolant Injection (LPCI) Outboard Injection Valve (1-FCV-74-52) Failure and 10CFR50.65(a)(1) corrective action plan b. Findings Introduction: The NRC inspectors identified a Severity Level (SL) IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) Part 21, Reporting of Defects and Noncompliance, for the licensees failure to report a known defect as soon as practicable, but in all cases within 60 days of discovery. More specifically, the licensee did not submit an interim report or notify the NRC in a timely manner pursuant to 10CFR21.21 regarding a manufacturing defect that caused a failure of the Unit 1 RHR Loop I outboard injection valve (1-FCV-74-052) on August 2, 2011. Description: On August 2, 2011, the Unit 1 Loop I LPCI Outboard Injection Valve (1- FCV-74-52), experienced a failure of the motor operator during performance of surveillance test procedure 1-SR-3.3.5.1.6(C I), Functional Testing of RHR Loop I Valve Logic and Interlocks. During this surveillance test, 1-FCV-74-52 was cycled successfully multiple times until it suddenly failed to reopen. The licensee promptly entered the required TS Limiting Condition of Operation (LCO) 3.5.1 seven day action statement, and initiated PER 410394 to also enter this issue into the corrective action program (CAP). The valve was repaired and returned to service within its TS allowed outage time (AOT). The actual failure of 1-FCV-74-52 did not involve a past operability concern or licensee performance deficiency. The root cause evaluation for PER 410394 was presented to the Corrective Action Review Board (CARB) on September 14, 2011. As part of the root cause analysis the licensee determined the motor operator failure was a manufacturing defect due to inadequate vendor assembly procedures and manuals for the SMB-5(T) motor operator which led to incomplete lug engagement of the clutching mechanism that subsequently rendered the valve non-functional. At the conclusion of the CARB, the NRC inspectors questioned the root cause team leader regarding the lack of a Part 21 evaluation and notification. The inspectors were informed that the licensee was working with the valve motor operator vendor on further corrective actions, and any required Part 21 notification would be addressed with the vendor. On September 20, 2011, PER 435444 was initiated stating that the root cause determination did not include a Part 21 evaluation. As a result of this PER, the licensee implemented their procedure NPG-SPP-03.5, Regulatory Reporting Requirements, and recognized this issue was potentially reportable per the requirements of 10CFR21.21. The inspectors subsequently concluded that the time of discovery for a Part 21 evaluation was September 14, 2011, for which 10CFR21.21 required the licensee to complete their Part 21 evaluation within the next 60 days, and then notify the NRC within the following seven days; or submit an interim report within 60 days of discovery if the Part 21 evaluation could not be completed within the 60 days. This timeframe required the issuance of a Part 21 interim report to the NRC by November 15, 2011, or a Part 21 initial Notification by November 20, 2011. However, no interim report was issued, and the licensee did not make an initial Part 21 Notification. The valve motor operator vendor (Flowserve) did submit the required Part 21 written report on November 29, 2011. The untimely Part 21 Notification was entered into licensees CAP as PER 487357. Analysis: The inspectors determined that the licensees failure to issue an interim report within 60 days or make an initial Notification of a Part 21 reportable condition constituted a violation of 10CFR21.21. Specifically, the licensee did not ensure that the failure of the 1-FCV-74-52 motor operator due to a manufacturing defect was evaluated and reported in accordance with the timeliness requirements of Part 21. This violation was evaluated using traditional enforcement because it had the potential for impacting the regulatory process. In accordance with the guidance in Section 2.2.2 and Section 6.9.d. of the NRC Enforcement Policy, the inspectors determined this violation was a Severity Level (SL) IV violation of low safety significance because the failure to report this condition did not substantially impact the Agency\\\'s regulatory responsibilities and the Agency would not have responded in a significantly different manner had the information been properly reported. The inspectors also concluded that failing to recognize this as a Part 21 reportable issue in a timely manner was a performance deficiency under the Reactor Oversight Process (ROP). In accordance with NRC IMC 0612, Appendix B, Issue Screening, the inspectors concluded that this performance deficiency was minor. Because this performance deficiency was minor and the violation was evaluated using Traditional Enforcement, a cross-cutting aspect is not assigned in accordance with IMC 0612. Enforcement: 10CFR21.21(a) required in part that the licensee shall evaluate deviations to identify defects associated with a substantial safety hazard as soon as practicable, but in all cases within sixty (60) days of discovery. Upon completion of this evaluation, an initial Notification to the Commission was required within seven days. However, if an evaluation of an identified defect potentially associated with a substantial safety hazard could not be completed within 60 days from discovery of the deviation, an interim report was required to be submitted to the Commission within the 60 days of discovery. Contrary to the above requirements, following the discovery of a manufacturing defect associated with the motor operator for 1-FCV-74-52, Loop I LPCI Outboard Injection Valve on September 14, 2011, the licensee failed to make either an initial Notification or submit an interim report within the time requirements of 10CFR21.21. The NRC was not notified of the Part 21 defect until the vendor (Flowserve) submitted a written report on November 29, 2011. This violation was a SL IV violation of low safety significance because the failure to report this condition did not substantively impact the Agency\\\'s regulatory responsibilities and the Agency would not have responded in a substantially different manner had the information been properly reported. Because this violation was of very low safety significance and it was entered into the licensees CAP as PER 487357, this violation was treated as an NCV, consistent with the NRC Enforcement Policy. This NCV is identified as NCV 05000259, 260, 296/2011005-01, Failure to Report a Valve Motor Operator Manufacturing Defect Pursuant to 10CFR21.21 in a Timely Manner.
05000259/FIN-2011002-0531 March 2011 23:59:59Browns FerryNRC identifiedRepeated Failure to Control Transient Combustibles in Proximity of the Independent Spent Fuel Storage FacilityA Severity Level IV, cited violation (VIO) of 10 CFR 72.212, Conditions of general license issued under 72.210, was identified by the inspectors for the licensees repetitive failure to adequately control transient combustible materials stored in the proximity of loaded dry casks on the ISFSI pad in accordance with site procedures. On February 3, 2011, while performing a routine walkdown of the ISFSI enclosed area, the inspectors observed seven storage cradles, multiple storage pallets and storage devices or cribbing located on or near the dry cask storage pad. The cradles, pallets and cribbing, were all constructed of wood products. The nearest items, were wood cradles located approximately 10 to 15 feet from the closest HI-STORM cask loaded with spent fuel. The other wood storage devices were approximately 20 feet from the closest loaded cask and were located both on and off the ISFSI pad. No apparent work was in progress at the time of discovery. The inspectors contacted responsible licensee personnel who promptly removed all the transient combustible material from the ISFSI exclusion area and initiated PER 318694. The licensee also performed an evaluation of the transient combustible loading for this material. This was the third occurrence identified by the inspectors of transient combustibles located in close proximity to HI-Storm casks loaded with spent fuel. The first two occurrences were on May 25, 2010 (see NCV 07200052/2010002-001, Transient Combustibles Stored Near Independent Spent Fuel Storage Facility in Excess of Amount Allowed), and on August 17, 2010 (see NOV 07200052/2010003-001, Transient Combustibles Stored Near Independent Spent Fuel Storage Facility in Excess of Amount Allowed), in both instances diesel fuel contained in vehicles left parked in close proximity to loaded HI-Storm casks was greater than the maximum allowed. According to NPG-SPP-18.4.7, Control of Transient Combustibles, the requirements and controls for handling and use of transient combustibles in proximity of the BFN ISFSI/Dry Cask Storage Pad were contained within drawings 0-47E201-1 and 0-47E201-2. In particular, drawing 0-47E201-2, ISFSI Fire Hazards Analysis Compensatory Actions, Item 11 stated that wooden structures facing the ISFSI were limited to a front face maximum height of 15 feet and a maximum width of 24 feet for a surface area total of 360 square feet, at a distance of 30 feet from the edge of the closest HI-STORM. Furthermore, General Operating Instruction (GOI) 0-GOI-300-1/ATT-12, Outside Operator Round Log, required operators to perform an inspection daily to ensure the ISFSI Pad and exclusion area were clear of the following: Flammable material such as wood, rags and plastic sheeting. If the ISFSI pad and exclusion area were not clear of these materials, then report the results to the Unit 3 Supervisor for evaluation of acceptability in accordance with drawing 0-47E201-2. Per 0-GOI-300-1/ATT-12 the ISFSI Pad exclusion area is defined as within 150 feet of the edges of the ISFSI Pad in all directions. Based upon discussion with the licensee and a review of work performed in the area, the inspectors determined that the licensee had allowed the wood cradles and cribbing to be left near a loaded HI-STORM cask for approximately one week from on or about January 26 to February 3, 2011. The licensee was performing work in the area to upright and inspect Multi Purpose Containers for the upcoming campaign. However, plant operators had not notified the Unit 3 US of the stored wooden material, and no evaluation had been performed on the acceptability of the transient combustible material as required by 0-GOI-300-1/ATT-12. Subsequent calculations by the licensee determined that the radiative heat load of the wood items was only about five percent of the allowed transient combustible loading limit.
05000259/FIN-2010005-0331 December 2010 23:59:59Browns FerryNRC identifiedRepeated Failure to Provide Complete and Accurate Information in LER 0500296/2009-003-02During an NRC inspection conducted on December 6, 2010, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below: 10 CFR 50.9, Completeness and Accuracy of Information, stated in part, that Information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on August 31, 2010, the licensee submitted a revised LER, as a corrective action for a previous 10 CFR 50.9 violation involving inoperability of the Unit 3 RCIC system, that was not complete and accurate in all material respects. The revised LER did not report the correct event date, nor did it describe prior corrective actions (e.g., maintenance and testing) taken for a previous related event and why these corrective actions did not prevent recurrence (as specifically detailed in NCV 05000296/2010003-03). This is a Severity Level IV violation.
05000259/FIN-2009005-0131 December 2009 23:59:59Browns FerryNRC identifiedFailure to Report an Automatic RPS Actuation While Shutdown Per 10 CFR 50.73A Severity Level IV, non-cited violation (NCV) of 10 CFR 50.72(b)(3)(iv)(A) and 10 CFR 50.73(a)(2)(iv)(A) were identified by the inspectors for the licensees failure to recognize that a valid automatic reactor protection system (RPS) actuation while shutdown was a reportable condition. Consequently, the licensee failed to make an eight hour report as required by 10CFR50.72 and submit a licensee event report (LER) within 60 days as required by 10CFR50.73. This issue was documented in the licensees corrective action program as Problem Evaluation Reports 172053, 178146, and 206168, and subsequently reported as LER 050- 260/2009-006. This finding was considered as traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. However, because this violation was of very low safety significance, was not repetitive or willful, and was entered into the licensees corrective action program, the NRC has characterized this violation as a Severity Level IV NCV in accordance with Section IV.A.3 and Supplement I of the NRC Enforcement Policy. The cause of this finding was directly related to the cross-cutting aspect of evaluating and properly prioritizing reportable conditions in the area of Problem Identification and Resolution because the licensee did not adequately prioritize their efforts to meet the LER timeliness requirement of 10CFR50.73 (P.1(c))
05000259/FIN-2009005-0231 December 2009 23:59:59Browns FerryNRC identifiedFailure to Report a Safety System Functional Failure Per 10 CFR 50.73A Severity Level IV non-cited violation (NCV) of 10 CFR 50.73(a)(2)(v)(D) and (vii)(D) was identified by the inspectors for the licensees failure to recognize a safety system functional failure of the Unit 1 High Pressure Coolant Injection (HPCI) system and submit a licensee event report (LER) within 60 days. This issue was documented in the licensees corrective action program as Problem Evaluation Reports 177206 and 204364, and subsequently reported as LER 050-259/2009-004. This finding was considered as traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. However, because this violation was of very low safety significance, was not repetitive or willful, and was entered into the licensees corrective action program, the NRC has characterized this violation as a Severity Level IV NCV in accordance with Section IV.A.3 and Supplement I of the NRC Enforcement Policy. The cause of this finding was directly related to the cross-cutting aspect of timely corrective actions in the area of Problem Identification and Resolution because the licensee failed to address previously identified deficiencies regarding the documentation of safety system mission times in a timely manner (P.1(d)).
05000259/FIN-2006002-0231 March 2006 23:59:59Browns FerryNRC identifiedFailure to Report a Safety System Functional Failure Per 10 CFR 50.73A Severity Level IV non-cited violation (NCV) of 10 CFR 50.73(a)(2)(v)(D) and (vii)(D) was identified by the inspectors for the licensees failure to submit a licensee event report for a safety system functional failure of the Unit 2 residual heat removal pressure suppression chamber containment isolation valves. This issue was documented in the licensees corrective action program as Problem Evaluation Report 99193. In Section IV of the NRC Enforcement Policy, the significance of violations involving the failure to make required reports is not dispositioned using the Reactor Oversight Programs Significance Determination Process. The licensees failure to provide a written event report does potentially impact the NRC\'s ability to carry out its regulatory function. However, because this failure to report per 10 CFR 50.73 did not actually impede or influence regulatory action, and the condition that required reporting under 10 CFR 50.73 was previously determined to be of very low safety significance in inspection report 05000260/2005003, the NRC has characterized the significance of this reporting violation as a Severity Level IV in accordance with Section IV.A.3 and Supplement I of the NRC Enforcement Policy.
05000259/FIN-2005008-0131 December 2005 23:59:59Browns FerryNRC identifiedEngineering did not Follow Procedures and Document on the Heat Shrink Data Sheets all the Parts Required to Install Four Splices on Multi-Conductor cables10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, in part, states that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. MAI-3.3 Paragraphs 6.2.11, 6.2.15, and 6.2.2.2.n.1, require engineering to specify on the heat shrink data sheet if a breakout boot is required. Contrary to the above, as of July 26, 2005, the licensee failed to specify on the heat-shrink data sheet that a breakout boot was required for the splices The licensee has concluded that the splice installation problems were limited to the four splices identified in the PER. The apparent causes for the installation deficiencies were determined to be the result of inadequate training in the area of field splices for field engineers in Maintenance/Modifications and Design Engineering Groups. The licensees proposed corrective actions included re-training personnel on Raychem splices. The failure to provide adequate instructions in the heat-shrink data sheets for installing the splices is a violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings. This is a Severity Level IV Violation per the criteria in Supplement II, Facility Construction, in the NRC Enforcement Policy. Because this Severity Level IV violation was identified by the licensee and has been entered into the licensees CAP (PER 86817), this violation is being treated as a Non-Cited Violation (NCV), consistent with Section VI.A of the NRC Enforcement Policy and will be identified as NCV 50-259/2005-008-01, Engineering Did Not Follow Procedures and Document on the Heat-Shrink Data Sheets All the Parts Required to Install Four Splices on Multi- Conductor Cables.
05000259/FIN-2005008-0231 December 2005 23:59:59Browns FerryNRC identifiedMeasures were not Adequate to Assure that the TOLs in 480V MOV Board 1B Cubicles, 14C-2 and 15C, were Strapped Out10 CFR 50, Appendix B, Criterion III, Design Control, requires that measures be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, on August 3, 2005, measures were not adequate to assure that the design changes (PIC 62058) for strapping out the TOLs in 480-V Reactor MOV Board Cubicles 14C-2 and 15C were correctly translated into work instructions. As a result of these inadequate measures, DCN 51090, Stage 24, and PIC 62058 were closed and the as-constructed drawings were issued, without the TOLs being strapped out in the plant. A Severity Level IV Violation was identified against the criteria in Supplement II, Facility Construction, of the NRC Enforcement Policy. This violation is being treated as an NCV, consistent with Section VI.A of the NRC Enforcement Policy, NCV 50-259/2005- 08-02, Measures Were Not Adequate to Assure that the TOLs in 480-V MOV Board 1B Cubicles 14C-2 and 15C Were Strapped Out. This issue was documented by the licensee in PER 89577. The licensee indicated that a special team will be formed to investigate the root cause and extent of condition for this design control problem.