IR 05000259/2022010
| 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
March 30, 2022
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. 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, Signed by McCoy, Gerald on 03/30/22 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 Enclosure
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 Report Aspect Section Mitigating Pending None (NPP) 71111.21N.05 Systems AV 05000259,05000260,05000296/202201 0-01 Open 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 Report Section Aspect Mitigating Pending None (NPP) 71111.21N.05 Systems AV 05000259,05000260,05000296/
2022010-01 Open 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 Type Designation Description or Title Revision or
Procedure Date
71111.21N.05 Calculations 0-TI-641 Time Critical Operator Actions 08/31/2021
BFN-0-22-016 Browns Ferry Nuclear Incipient Detection FPRA Rev. 0
Sensitivity
EDQ0009992012000115 Non-Power Operations Analysis Rev. 35
EDQ099920110010 Nuclear Safety Capability Analysis Rev. 57
R06 160202 313 BFN Verification and Validation NFPA 05 FSS 02/02/2016
Operator Actions
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
RIMS R06 160202 361 Verification and Validation for NFPA 805 Recovery
Actions for 3-FSS-16-2
Corrective Action CR 1488947 BFN 2019 TFPI - BFN 2019 TFPI - CO2 Boundary 02/06/2019
Documents Door Found Unsecured
CR 1489212 BFN 2019 TFPI Procedure Change for Quarterly 02/07/2019
Inspection of Emergency Equipment
CR 1489222 BFN 2019 TFPI Conduction of Fire Ops Procedural 02/07/2019
Enhancement
CR 1490451 BFN 2019 TFPI Fire Extinguisher Placement 02/12/2019
Exceeds Allowable Distance
CR 1490459 BFN 2019 TFPI Need WO to Add Fire Extinguishers 02/12/2019
in the U-1/2 & U-3 Diesel Bldgs.
CR 1490658 BFN 2019 TFPI - NFPA 805 Licensing Basis 02/13/2019
Potential Non-Conformance
CR 1730278 2021 BFN NFPA 805 Fire Protection Self- 10/22/2021
Assessment - Learning Opportunity
CR 1731951 2021 BFN NFPA 805 Fire Protection Self- 10/29/2021
Assessment - Learning Opportunity
Inspection Type Designation Description or Title Revision or
Procedure Date
Corrective Action CR 1751964 NRC 2022 TFPI - Incipient Detection Systems not 02/02/2022
Documents tested IAW NFPA Codes and Vendor
Resulting from Recommendations
Inspection CR 1753800 0-FSS-2-3 Valve Location Discrepancy 02/09/2022
CR 1754884 Revise 0-FSS-1-4 02/14/2022
CR 1755019 Error in Attachment G of the BFN NFPA 805 02/15/2022
License Amendment Request (LAR)
CR 1752054 0-FSS-001 Attachment 4 Posted in 480V Shutdown 02/02/2022
Board Rooms
CR 1752451 NRC 2022 TFPI - Portable Space Heater Does Not 02/03/2022
Meet Procedural Requirements
CR 1753102 NRC 2022 FPTI - EDQ099920110010 Error 02/07/2022
CR 1755115 NRC 2022 TFPI - Learning Opportunity - Transient 02/15/2022
Combustibles Found Under Stairwell
CR 1755125 2022 NRC Triennial Fire Protection Inspection - 02/15/2022
Performance Deficiency
CR 1755346 Electrical Raceway Fire Barrier System (ERFBS) for 02/16/2022
Conduit 2B98-IID has Damage
CR 1755414 NRC 2022 TFPI - Material found not meeting 02/16/2022
Chemical Traffic Control Requirements
Drawings 3-47E610-74-1 Mechanical Control Diagram Residual Heat Rev. 36
Removal System
3-47E811-1 Flow Diagram Residual Heat Removal System Rev. 73
3-47E811-1 Unit 3 Flow Diagram Residual Heat Removal 04/20/1970
System
8.4-3 4160V Shutdown Auxiliary Power Schematic Rev. 28
Diagram
Engineering DCN 70943 Reroute Cables 3ES3027-II Out of FZ 03-01 and Rev. A
Changes 03-03
Engineering RIMS R69 210810 438 Retiming Validation for FSS Procedures 07/22/2021
Evaluations
Fire Plans FPR-Volume 2, Pre-Fire Plans for Browns Ferry Nuclear Plant Rev. 68
Reactor Building Unit 1
Inspection Type Designation Description or Title Revision or
Procedure Date
FPR-Volume 2, Pre-Fire Plans for Browns Ferry Nuclear Plant Rev. 68
Reactor Building Unit 3
FPR-Volume 2, Pre-Fire Plans for Browns Ferry Nuclear Plant Rev. 68
Control Bay U-2
Miscellaneous BFN-VTD-CI05-0010 Safe Fire Detection Inc. / Cirrus Pro Series Rev. 0
Engineers Manual
Procedures 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 Rev. 22
Electrical Conduit, Cable Trays, Boxes,
Containment Electrical Penetrations, Electric
Conductor Seal Assemblies, Lighting and
Miscellaneous Systems
G-98 INSTALLATION, MODIFICATION, AND Rev. 15
MAINTENANCE OF ELECTRICAL RACEWAY
FIRE BARRIER SYSTEMS
NPG-SPP-18.4.5 Fire Protection Quality Assurance Rev. 3
NPG-SPP-18.4.7 Control of Transient Combustibles Rev. 15
NPG-SPP-22.300 Corrective Action Program Rev. 23
Work Orders 119644375 Loop I RHR Simulated Actuation Test 02/26/2020
20134724 Diesel Generator B Operability Test (4KV Shutdown 12/21/2020
Board Operation)
20134950 0-SI-4.11.A.1 - Annual Smoke Detector Functional 06/25/2020
Test
20561594 0-SI-4.11.A.2(2) - Supervised Fire System Circuits 03/22/2022
Operability Test
21165782 0-SI-4.11.A.2(2) - Supervised Fire System Circuits 01/14/2021
Operability Test
21352032 0-SI-4.11.A.1 - Annual Smoke Detector Functional 04/24/2021
Test
Inspection Type Designation Description or Title Revision or
Procedure Date
21379875 0-SI-4.11.A.2(2) - Supervised Fire System Circuits 07/24/2021
Operability Test
21533972 52 Week RHR HX 3B Performance Testing 08/16/2021
21165837 O-SI-4.11.G.1.A(1) - VISUAL INSPECTION OF 01/19/2021
21701306 0-SI-4.11.B.1.F(2) - Electric Fire Pump Capability 12/15/2021
Test
9