IR 05000259/2022010

Triennial Fire Protection Inspection Report 05000259/2022010 and 05000260/2022010 and 05000296/2022010 and Apparent Violation

ML22089A155
Person / Time
Site:	Browns Ferry
Issue date:	03/30/2022
From:	Philipp Braaten NRC/RGN-II/DRS/EB2
To:	Jim Barstow Tennessee Valley Authority
References
IR 2022010
Download: ML22089A155 (12)

Text

SUBJECT:

BROWNS FERRY NUCLEAR PLANT - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000259/2022010 AND 05000260/2022010 AND 05000296/2022010 AND APPARENT VIOLATION

Dear Mr. Barstow:

On February 17, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Browns Ferry Nuclear Plant and discussed the results of this inspection with Mr. Daniel Komm and other members of your staff. The results of this inspection are documented in the enclosed report.

Section 71111.21N.05 of the enclosed report discusses a finding with an associated apparent violation for which the NRC has not yet reached a preliminary significance determination. The inspectors identified a finding and associated Apparent Violation of License Condition C.13, C.14, and C.7 for Units 1, 2, and 3 respectively when the licensee failed to perform adequate testing on credited incipient fire detection systems.

We intend to issue our final safety significance determination and enforcement decision, in writing, within 90 days from the date of this letter. The NRCs significance determination process (SDP) is designed to encourage an open dialogue between your staff and the NRC; however, neither the dialogue nor the written information you provide should affect the timeliness of our final determination. We ask that you promptly provide any relevant information that you would like us to consider in making our determination. We are currently evaluating the significance of this finding and will notify you in a separate correspondence once we have completed our preliminary significance review. You will be given an additional opportunity to provide additional information prior to our final significance determination unless our review concludes that the finding has very low safety significance (i.e., Green).

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for 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 Browns Ferry Nuclear Plant.

March 30, 2022 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, Gerald J. McCoy, Chief Engineering Branch 2 Division of Reactor Safety 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:

05000259/2022010, 05000260/2022010, and 05000296/2022010

Enterprise Identifier:

I-2022-010-0025

Licensee:

Tennessee Valley Authority

Facility:

Browns Ferry Nuclear Plant

Location:

Decatur, AL

Inspection Dates:

January 31-February 18, 2022

Inspectors:

P. Braaten, Senior Reactor Inspector

W. Monk, Senior Reactor Inspector

D. Strickland, Reactor Inspector

Approved By:

Gerald J. McCoy, Chief

Engineering Branch 2

Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial fire protection inspection 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

Failure to perform adequate testing on incipient fire detection systems.

Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Pending AV 05000259,05000260,05000296/202201 0-01 Open None (NPP)71111.21N.05 The inspectors identified a finding and associated Apparent Violation of License Condition C.13, C.14, and C.7 for Units 1, 2, and 3, respectively, when the licensee failed to perform adequate testing on credited incipient fire detection systems.

Additional Tracking Items

None.

INSPECTION SCOPES

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.

REACTOR SAFETY

71111.21N.05 - Fire Protection Team Inspection (FPTI) Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)

The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis (FHA) or safe shutdown analysis (SSA).

(1) Unit 3 System 74 - Low Pressure Coolant Injection

(2) Unit 2 System 211 - 4kV Shutdown Boards A, B, C, and D

(3) Unit 2 Auxiliary Instrument Room Incipient Fire Detection System - Compartment 16-M

(4) Unit 1 General Area Pre-Action Sprinkler System - Compartment 01-04

Fire Protection Program Administrative Controls (IP Section 03.02) (1 Sample)

The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis. If applicable, ensure that the licensees FPP contains adequate procedures to implement the selected administrative control. Verify that the selected administrative control meets the requirements of all committed industry standards.

(1) Transient Combustible Control Program

Fire Protection Program Changes/Modifications (IP Section 03.03) (1 Sample)

The inspectors verified the following:

a. Changes to the approved FPP do not constitute an adverse effect on the ability to safely shutdown.

b. The adequacy of the design modification, if applicable.

c. Assumptions and performance capability stated in the SSA have not been degraded through changes or modifications.

d. The FPP documents, such as the Updated Final Safety Analysis Report, fire protection report, FHA, and SSA were updated consistent with the FPP or design change.

e. Post-fire SSD operating procedures, such as abnormal operating procedures, affected by the modification were updated.

(1) DCN

INSPECTION RESULTS

Failure to perform adequate testing on incipient fire detection systems.

Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Pending AV 05000259,05000260,05000296/

2022010-01 Open None (NPP)71111.21N.05 The inspectors identified a finding and associated Apparent Violation of License Condition C.13, C.14, and C.7 for Units 1, 2, and 3, respectively, when the licensee failed to perform adequate testing on credited incipient fire detection systems.

Description:

As part of transitioning to a risk informed fire protection program at Browns Ferry, the site installed air sampling incipient fire detection systems in several fire areas. The Auxiliary Instrument rooms on all three units were determined to be risk significant areas and the prompt detection provided from incipient fire detection provided the requisite risk reductions needed to fully transition to a risk informed fire protection program under 10 CFR 50.48(c). The incipient fire detection systems provided this risk reduction by providing a means to promptly detect a fire or even potential fire by sampling air in selected electrical cabinets. In order for these systems to function properly and within their design basis, the systems must show a balanced air flow from all sampling points. Additionally, the time required to detect products of combustions, known as the transport time, must be within a certain threshold. Annual verification of the transport time is required to determine system operability.

While reviewing the work orders that documented the completion of the annual testing of the incipient fire detection systems at Browns Ferry, the inspectors noted that the annual surveillance test did not include a transport time test. The inspectors requested the vendor manual for the installed systems as well as the code of record and licensing commitments for the detection systems. In reviewing the vendor manual and the applicable National Fire Protection Association code, NFPA 72-2010, "National Fire Alarm and Signaling Code," the inspectors noted that the annual testing of air sampling detection devices must include a transport time test.

The NRC inspectors raised these concerns with the licensee who acknowledged that the affected systems only completed the requisite transport time test as part of system commissioning and had not been subsequently tested. The licensee declared the systems inoperable and implemented appropriate compensatory actions. The site then initiated a test to validate the transport time for all the installed incipient systems that are credited for risk reduction, systems 1/2/3-SDET-026-0103A, which are installed in the associated units Auxiliary Instrument room. Upon completion of these tests, the licensee indicated that the installed systems did not pass the transport time requirements of the NFPA codes and NRC commitments.

Corrective Actions: The licensee declared the incipient detection systems inoperable and established fire watches in the affected fire areas.

Corrective Action References: The licensee captured this in CR 1751964.

Performance Assessment:

Performance Deficiency: The licensee's failure to perform adequate testing of the installed air sampling incipient fire detection systems was a performance deficiency. Specifically, the licensee failed to conduct annual transport time testing of the systems as required by NFPA codes.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Response to Contingency Events attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the loss of the incipient fire detection systems greatly reduces the licensees ability to promptly detect and respond to a significant plant fire in a timely manner.

Significance: The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The issue was determined to impact Fixed Fire Protection Systems and was screened with question 1.4.2-A. The inspectors answered No and determined that further screening is required. Per section 1.5 of the SDP, the NRC is utilizing the fire PRA of the licensee to assess the risk. Given the scope of the issue, the licensee is working to provide an accurate risk assessment of the issue for the NRC to review.

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. The licensee completed transition to NFPA 805 in October 2015 and all programs and surveillances were developed and implemented at that time. Therefore, this issue is not indicative of current licensee performance.

Enforcement:

Violation: Browns Ferry operating license condition C.13, C.14, and C.7 for Units 1, 2, and 3, respectively, states that the site shall implement and maintain in effect all provisions of the approved protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c).

NFPA 805, as incorporated by 10 CFR 50.48(c), section 3.2.3, Procedures, states that procedures shall be established for implementation of the fire protection program.

Contrary to the above, since October 28, 2015, the licensee did not establish adequate testing procedures for the incipient fire detection system. Specifically, the licensee was not conducting the required annual transport time testing as specified by NFPA codes.

Enforcement Action: This violation is being treated as an apparent violation pending a final significance (enforcement) determination.

EXIT MEETINGS AND DEBRIEFS

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

On February 17, 2022, the inspectors presented the triennial fire protection inspection results to Mr. Daniel Komm and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

0-TI-641

Time Critical Operator Actions

08/31/2021

BFN-0-22-016

Browns Ferry Nuclear Incipient Detection FPRA

Sensitivity

Rev. 0

EDQ0009992012000115

Non-Power Operations Analysis

Rev. 35

EDQ099920110010

Nuclear Safety Capability Analysis

Rev. 57

R06 160202 313

BFN Verification and Validation NFPA 05 FSS

Operator Actions

2/02/2016

RIMS R06 160202 314

Verification and Validation NFPA 805 Recovery

Actions for FA 1-1

RIMS R06 160202 342

Verification and Validation for NFPA 805 Recovery

Actions for FA 16-1

Calculations

RIMS R06 160202 361

Verification and Validation for NFPA 805 Recovery

Actions for 3-FSS-16-2

CR 1488947

BFN 2019 TFPI - BFN 2019 TFPI - CO2 Boundary

Door Found Unsecured

2/06/2019

CR 1489212

BFN 2019 TFPI Procedure Change for Quarterly

Inspection of Emergency Equipment

2/07/2019

CR 1489222

BFN 2019 TFPI Conduction of Fire Ops Procedural

Enhancement

2/07/2019

CR 1490451

BFN 2019 TFPI Fire Extinguisher Placement

Exceeds Allowable Distance

2/12/2019

CR 1490459

BFN 2019 TFPI Need WO to Add Fire Extinguishers

in the U-1/2 & U-3 Diesel Bldgs.

2/12/2019

CR 1490658

BFN 2019 TFPI - NFPA 805 Licensing Basis

Potential Non-Conformance

2/13/2019

CR 1730278

21 BFN NFPA 805 Fire Protection Self-

Assessment - Learning Opportunity

10/22/2021

Corrective Action

Documents

CR 1731951

21 BFN NFPA 805 Fire Protection Self-

Assessment - Learning Opportunity

10/29/2021

71111.21N.05

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CR 1751964

NRC 2022 TFPI - Incipient Detection Systems not

tested IAW NFPA Codes and Vendor

Recommendations

2/02/2022

CR 1753800

0-FSS-2-3 Valve Location Discrepancy

2/09/2022

CR 1754884

Revise 0-FSS-1-4

2/14/2022

CR 1755019

Error in Attachment G of the BFN NFPA 805

License Amendment Request (LAR)

2/15/2022

CR 1752054

0-FSS-001 Attachment 4 Posted in 480V Shutdown

Board Rooms

2/02/2022

CR 1752451

NRC 2022 TFPI - Portable Space Heater Does Not

Meet Procedural Requirements

2/03/2022

CR 1753102

NRC 2022 FPTI - EDQ099920110010 Error

2/07/2022

CR 1755115

NRC 2022 TFPI - Learning Opportunity - Transient

Combustibles Found Under Stairwell

2/15/2022

CR 1755125

22 NRC Triennial Fire Protection Inspection -

Performance Deficiency

2/15/2022

CR 1755346

Electrical Raceway Fire Barrier System (ERFBS) for

Conduit 2B98-IID has Damage

2/16/2022

Corrective Action

Documents

Resulting from

Inspection

CR 1755414

NRC 2022 TFPI - Material found not meeting

Chemical Traffic Control Requirements

2/16/2022

3-47E610-74-1

Mechanical Control Diagram Residual Heat

Removal System

Rev. 36

3-47E811-1

Flow Diagram Residual Heat Removal System

Rev. 73

3-47E811-1

Unit 3 Flow Diagram Residual Heat Removal

System

04/20/1970

Drawings 8.4-3

4160V Shutdown Auxiliary Power Schematic

Diagram

Rev. 28

Engineering

Changes

DCN 70943

Reroute Cables 3ES3027-II Out of FZ 03-01 and

03-03

Rev. A

Engineering

Evaluations

RIMS R69 210810 438

Retiming Validation for FSS Procedures

07/22/2021

Fire Plans

FPR-Volume 2,

Pre-Fire Plans for Browns Ferry Nuclear Plant

Reactor Building Unit 1

Rev. 68

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

FPR-Volume 2,

Pre-Fire Plans for Browns Ferry Nuclear Plant

Reactor Building Unit 3

Rev. 68

FPR-Volume 2,

Pre-Fire Plans for Browns Ferry Nuclear Plant

Control Bay U-2

Rev. 68

Miscellaneous

BFN-VTD-CI05-0010

Safe Fire Detection Inc. / Cirrus Pro Series

Engineers Manual

Rev. 0

0-FSS-001

Fire Safe Shutdown Procedure for Fire Entry

Rev. 7

0-FSS-16-1

Fire Safe Shutdown Procedure for FA 16-1

Rev. 15

0-FSS-16-2

Fire Safe Shutdown Procedure for FA 16-2

Rev. 10

0-FSS-2-4

Fire Safe Shutdown Procedure

Rev. 10

BFN-50-7026

HIGH PRESSURE FIRE PROTECTION SYSTEM

Rev. 12

BFN-50-7500

NFPA 805 Fire Protection

Rev. 1

G-40

Installation, Modification and Maintenance of

Electrical Conduit, Cable Trays, Boxes,

Containment Electrical Penetrations, Electric

Conductor Seal Assemblies, Lighting and

Miscellaneous Systems

Rev. 22

G-98

INSTALLATION, MODIFICATION, AND

MAINTENANCE OF ELECTRICAL RACEWAY

FIRE BARRIER SYSTEMS

Rev. 15

NPG-SPP-18.4.5

Fire Protection Quality Assurance

Rev. 3

NPG-SPP-18.4.7

Control of Transient Combustibles

Rev. 15

Procedures

NPG-SPP-22.300

Corrective Action Program

Rev. 23

119644375

Loop I RHR Simulated Actuation Test

2/26/2020

20134724

Diesel Generator B Operability Test (4KV Shutdown

Board Operation)

2/21/2020

20134950

0-SI-4.11.A.1 - Annual Smoke Detector Functional

Test

06/25/2020

20561594

0-SI-4.11.A.2(2) - Supervised Fire System Circuits

Operability Test

03/22/2022

21165782

0-SI-4.11.A.2(2) - Supervised Fire System Circuits

Operability Test

01/14/2021

Work Orders

21352032

0-SI-4.11.A.1 - Annual Smoke Detector Functional

Test

04/24/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

21379875

0-SI-4.11.A.2(2) - Supervised Fire System Circuits

Operability Test

07/24/2021

21533972

Week RHR HX 3B Performance Testing

08/16/2021

21165837

O-SI-4.11.G.1.A(1) - VISUAL INSPECTION OF

FIRE WRAPS

01/19/2021

21701306

0-SI-4.11.B.1.F(2) - Electric Fire Pump Capability

Test

2/15/2021