UNITED STATES

NUCLEAR REGULATORY COMMISSION REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257

October 29, 2918 EA-18-101 Mr. J. W. Shea Vice President, Nuclear Regulatory Affairs and Support Services Tennessee Valley Authority 1101 Market Street, LP 4A Chattanooga, TN 37402-2801 SUBJECT: BROWNS FERRY NUCLEAR PLANT – NRC INTEGRATED INSPECTION REPORT 05000259/2018003, 05000260/2018003, AND 05000296/2018003 Dear Mr. Shea: On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Browns Ferry Nuclear Plant, Units 1, 2, and 3. On October 19, 2018, the NRC inspectors discussed the results of this inspection with Lang Hughes and other members of your staff. The results of this inspection are documented in the enclosed report. NRC inspectors documented one Severity Level IV violation with no associated finding. This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy. Further, inspectors documented a licensee-identified violation which was determined to be of very low safety significance in this report. This licensee-identified violation closes out Apparent Violation (AV) 05000259, 260, 296/2018002-03 Failure to Analyze for a Water Hammer Event due to Spurious Operation of Residual Heat Removal Service Water (RHRSW) Valves During a Fire Event. The NRC is treating this violation as a NCV consistent with Section 2.3.2.a of the Enforcement Policy. If you contest any of the violations or significance of these NCVs, 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, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Browns Ferry Nuclear Plant.

J. Shea 2

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 05000259/2018003, 05000260/2018003 and 05000296/2018003 cc: Distribution via ListServ

J. Shea 3

SUBJECT: BROWN FERRY NUCLEAR PLANT – NRC INTEGRATED INSPECTION

REPORT 05000259/2018003, 05000260/2018003 and 05000296/2018003 Dated October 29, 2018

DISTRIBUTION: M. Kowal, RII K. Sloan, RII OE Mail RIDSNRRDIRS PUBLIC RidsNrrPMBrownsFerryResource

PUBLICLY AVAILABLE NON-PUBLICLY AVAILABLE SENSITIVE NON-SENSITIVE

ADAMS: Yes ACCESSION NUMBER:_________________________ SUNSI REVIEW COMPLETE FORM 665 ATTACHED

OFFICE RII/DRP RII/DRP RII/DRP RII/DRS RII/DRP RII/DRP RII/DRP NAME TSTEPHEN MKIRK NHOBBS JVIERA DLANYI SNINH JWOROSILO DATE 10/24/18 10/22/18 10/23/18 10/22/18 10/22/18 10/26/18 10/25/18 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

.OFFICE RII/DRP NAME AMASTERS DATE 10/29/18 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

OFFICIAL RECORD COPY DOCUMENT NAME: G:\DRPII\RPB5\BROWNS FERRY\REPORTS\2018 INSPECTION REPORTS\BF IR 2018-03.DOCX

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report Docket Nos.: 50-259, 50-260, and 50-296 License Nos.: DPR-33, DPR-52, and DPR-68 Report No.: 05000259/2018003, 05000260/2018003, and 05000296/2018003 Enterprise Identifier: I-2018-003-0035 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 Dates: July 1, 2018 through September 30, 2018 Inspectors: T. Stephen, Senior Resident Inspector M. Kirk, Resident Inspector N. Hobbs, Resident Inspector D. Lanyi, Senior Operations Engineer J. Viera, Operations Engineer Approved by: Anthony D. Masters, Chief Reactor Projects Branch 5 Division of Reactor Projects

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SUMMARY The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensee’s performance by conducting quarterly integrated baseline inspections and an emergency preparedness program inspection at Browns Ferry Nuclear Plant, Units 1, 2, and 3 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC’s 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, and additional items are summarized in the table below. A licensee-identified non-cited violation (NCV) is documented in report section 71152.

List of Findings and Violations

Main Steam Relief Valves Lift Settings Outside of Technical Specifications Required Setpoints Cornerstone

Significance Cross-cutting Aspect

Report Section

Not Applicable Severity Level (SL) IV NCV 05000296/2018-003-01 Closed

Not applicable 71153

A 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.

Additional Tracking Items

Type Issue Number Title Report Section

Status

AV 05000259,260,296/2018002-03

Failure to Analyze for a Water Hammer Event due to Spurious Operation of Residual Heat Removal Service Water (RHRSW) Valves During a Fire Event

71152 Closed

LER 05000296/2018-003-00 Misadjusted Switch Results in Condition Prohibited by Technical Specifications

71153 Closed

LER 05000296/2018-004-00 Main Steam Relief Valves Lift Settings Outside of Technical Specifications Required Setpoints

71153 Closed

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PLANT STATUS Unit 1 operated at 100 percent rated thermal power (RTP) until August 10, 2018, when it performed a downpower to 79 percent RTP due to 1A high pressure feedwater heater string isolation. The unit remained at 79 percent for the remainder of the inspection period. Unit 2 operated at 100 percent RTP for the duration of the inspection period. Unit 3 began the inspection period in a controlled power ascension associated with its extended power uprate (EPU). The unit achieved 100 percent power on July 13, 2018. On September 22, 2018, power was reduced to 72 percent RTP for 3A high pressure feedwater heater string isolation. The unit remained at 72 percent RTP for the remainder of the inspection period. 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 performed plant status activities described in IMC 2515 Appendix D, “Plant Status” and conducted routine reviews using IP 71152, “Problem Identification and Resolution.” 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

71111.01 – Adverse Weather Protection

External Flooding (1 Sample)

The inspectors evaluated readiness to cope with external flooding on September 17, 2018. 71111.04 - Equipment Alignment

Partial Walkdown (4 Samples) The inspectors evaluated system configurations during partial walkdowns of the following systems/trains: (1) Unit 1 & 2, high pressure coolant injection (HPCI) on August 14, 2018 including the lube

oil system (2) standby gas treatment (SBGT) system trains B and C on August 21, 2018 while train A

was inoperable for maintenance (3) Unit 2 residual heat removal service water (RHRSW) system for A, B, C, and D trains on

August 23, 2018

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(4) Unit 3 reactor core isolation cooling (RCIC) on September 12, 2018, including verification of preventative maintenance performed during the Unit 3 spring outage

71111.05AQ - Fire Protection Annual/Quarterly

Quarterly Inspection (5 Samples) The inspectors evaluated fire protection program implementation in the following selected areas:

(1) reactor building Unit 1 electric board room 1A, Fire Area 05, on August 7, 2018 (2) cable spreading room B, Fire Area 16-A on August 14, 2018 (3) reactor building Unit 2 Elevation 593’ North, Fire Area 2-3, on August 14, 2018 (4) Unit 2 battery and battery board room, Fire Area 18 on September 6, 2018 (5) intake cable tunnel, Fire Area 25-1 on September 25, 2018

71111.06 - Flood Protection Measures

Internal Flooding (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the Unit 1 1A and 1B electric board rooms on September 7, 2018.

71111.07 – Heat Sink Performance

Heat Sink (1 Sample) The inspectors performed an annual review of Browns Ferry’s ultimate heat sink including the intake channel on September 21, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample) The inspectors observed and evaluated a licensed operator requalification simulator training scenario for the Group 5 operating crew on the Unit 3 simulator involving use of the new anticipated transient without scram (ATWS) procedures and a scenario testing the crew’s response to an emergency diesel generator (EDG) with a low battery cell level, a failed closed main steam isolation valve (MSIV), and lowering condenser vacuum on July 30, 2018. Operator Requalification Program (1 Sample) The inspectors evaluated the operator requalification program from September 10-14, 2018.

Operator Performance (1 Sample) The inspectors observed and evaluated the following • Unit 3 combined intermediate valve manipulations on July 3, 2018.

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• Unit 3 power ascension and the initial testing associated with being at the new licensed 100 percent RTP on July 13, 2018.

• Unit 3 reactor feed pump turbine testing at 100 percent RTP on August 2, 2018.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness (2 Samples) The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Unit 1, 2, and 3 Main Steam System Alternate Leakage Path Boundary Function 001C-E

(a)(1) Plan (2) Maintenance Rule 11th Periodic Report (January 2016 to December 2017)

71111.13 - Maintenance Risk Assessments and Emergent Work Control (3 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Emergent work associated with unplanned Unit 1 HPCI inoperability during D EDG

extended outage on July 10, 2018. (2) Planned risk, associated with inoperable main bank battery 3 and battery board 3 on

July 25, 2018. (3) Planned risk due to a high hazard lift associated with C2 RHRSW pump motor

replacement on September 27, 2018. 71111.15 - Operability Determinations and Functionality Assessments (7 Samples)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 1 and 2, Common cause evaluation to support operability of A, B and C EDGs after

identifying two degraded conditions on D EDG during preventative maintenance (2) Unit 3, HPCI operability after failure of check valve 3-CKV-73-45 during Local Leak Rate

Testing (condition reports (CRs) 1391831, 1398557) (3) Unit 2, Reactor Steam Dome Pressure Transmitter 2-PIS-68-95 Prompt Determination of

Operability following its failure (CR 1442623) (4) Unit 1 Radiation Monitor 1-RM-90-141/143 for the Reactor and Refueling Zone

Ventilation determination of operability following its repair (CR 1432867) (5) Unit 3, Functionality Evaluation of Alternate Leakage Treatment pathway following the

failure of valves to stroke open during a surveillance on July 30, 2018 (CR 1435680) (6) Unit 2, MSIV – Closure function after identifying Environmental Qualification

discrepancies associated with limit switch conductor insulation (CR 1449196) (7) Units 1, 2, and 3 Standby Liquid Control – Anticipated Transient Without Scram

calculation updated for EPU (CR 149832)

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71111.18 – Plant Modifications (2 Samples)

The inspectors evaluated the following plant modifications: (1) Unit 3, pressure transmitter type change for reactor steam dome pressure transmitters 3-

PIS-68-95 and 3-PIS-68-96 (2) Unit 1, 2, and 3 temporary fan installed in supplemental diesel building during cable

installations for the emergency high pressure makeup system 71111.19 - Post Maintenance Testing (5 Samples)

The inspectors evaluated the following post maintenance tests:

(1) Unit 1 and 2, post maintenance testing following an extended outage on D EDG for a six year inspection and maintenance on July 8, 2018.

(2) Unit 3, post maintenance testing following replacing the hand switch to Breaker 1838 (Tie breaker to 3A EDG) on July 31, 2018.

(3) Unit 2, post maintenance testing following recalibration of pressure transmitter 2-PIS-68-95 for reactor steam dome pressure ‘C’ channel on August 28, 2018.

(4) Unit 2, post maintenance testing following the replacement and calibration of the analog trip unit (ATU) for pressure transmitter 2-PIS-68-95 on September 4, 2018.

(5) Various Unit 3 integrated systems testing per 3-TI-700, 3-TI-701, 3-TI-130 and 3-TI-131 at extended power uprate conditions from July 1 to July 13, 2018 when the unit achieved the new licensed operating power of 3952MWt.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests: Routine (5 Samples) (1) Unit 1, HPCI System Vent of Discharge Piping on July 11, 2018 (2) Unit 1 and 2, B EDG Monthly Operability Test (0-SR-3.8.1.1(B)) on July 24, 2018 (3) Unit 1, 2, and 3, Main Bank 3 Battery Service Test (3-SR-3.8.4.3) on July 24, 2018 (4) Unit 1, Standby Liquid Control Pump Functional Test (1-SI-4.4.A.1) on August 9, 2018 (5) Unit 2, HPCI Comprehensive Pump Test (2-SR-3.5.1.7(COMP)) on September 13, 2018

Containment Isolation (1 Sample)

(1) ECI-0-000-MOV009, Testing of Motor Operated Valves for 3-MVOP-001-0055 Main

Steam Line Drain Isolation valve for HPCI and RCIC that was completed on February 26, 2018

71114.06 - Drill Evaluation

Drill/Training Evolution (2 Samples) The inspectors evaluated emergency preparedness training drills on July 11, 2018 and August 1, 2018.

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OTHER ACTIVITIES – BASELINE

71151 - Performance Indicator Verification

The resident inspectors verified licensee performance indicators submittals listed below for the period from July 1, 2017, through June 30, 2018. (9 Samples) (1) Units 1, 2, and 3 mitigating systems performance index (MSPI) for cooling water

systems (2) Units 1, 2, and 3 MSPI for emergency AC power system (3) Units 1, 2, and 3 MSPI for residual heat removal system

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (1 Samples) The inspectors reviewed the licensee’s implementation of its corrective action program related to the following issues: (1) CRs 1139620 and 1397087, related to the AV 05000259, 260, 296/2018-002-03: failure

to analyze for a water hammer event due to spurious operation of residual heat removal service water (RHRSW) valves during a fire event.

71153 - Follow-up of Events and Notices of Enforcement Discretion

Events (1 Sample) The inspectors evaluated response to the following event: Notice of Unusual Event (NOUE) due to a small fire from a 120 VAC power supply in the Unit 3 condensate demineralizer control panel in the turbine building that burned more than 15 minutes (extinguished in 18 minutes) on August 22, 2018. Licensee Event Reports (2 Samples) The inspectors evaluated the following licensee event reports (LER) which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx : (1) LER 05000296-2018-003-00, Misadjusted Switch Results in Condition Prohibited by

Technical Specifications. A violation related to this issue was documented in inspection report 05000259, 260, 296/2018001 (ADAMS Accession No. ML18128A153)

(2) LER 05000296/2018-004-00, Main Steam Relief Valves Lift Settings Outside of Technical Specifications Required Setpoints.

OTHER ACTIVITIES – TEMPORARY INSTRUCTIONS, INFREQUENT, AND ABNORMAL 60855.1 – Operation of an Independent Spent Fuel Storage Installation (2 samples)

(1) The inspectors observed the licensee’s independent spent fuel storage installation cask loading campaign on July 16 – August 24, 2018.

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(2) The inspectors also evaluated changes to ISFSI programs and procedures to verify that changes were made consistent with the license and/or certificate of compliance.

71004 - Power Uprate Summary of Power Uprate Inspection Samples Contained in this Report:

Integrated Plant Operations at the Uprated Power Level (Unit 3) (1) Power ascension above previous thermal power limit (Section 71111.11).

Monitor Major Integrated Tests (Unit 3) (1) Various Unit 3 integrated systems testing per 3-TI-700, 3-TI-701, 3-TI-130, and 3-TI-131

at extended power uprate conditions from July 1, 2018 to July 13, 2018 (Section 71111.19).

This completes IP 71004 for Unit 3 Extended Power Uprate. INSPECTION RESULTS Licensee Identified Non-Cited Violation 71152 - Problem Identification and Resolution This violation of very low safety significant was identified by the licensee and has been entered into the licensee corrective action program and is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy. Violation: Violation: 10 CFR 50.48(c)(3)(ii) required, in part, the licensee to complete its implementation of the methodology in Chapter 2 of NFPA 805 (including all required evaluations and analyses) and, upon completion, modify the fire protection plan. NFPA 805 Chapter 2, section 2.4.2.2.1, Circuits Required in Nuclear Safety Functions required, in part, that circuits required for the nuclear safety functions shall be identified. This includes circuits that are required for operation or that result in the mal-operation of the equipment identified. This evaluation shall consider fire-induced failure modes such as hot shorts (external and internal), open circuits, and shorts to ground, to identify circuits that are required to support the proper operation of components required to achieve the nuclear safety performance criteria, including spurious operation and signals. Contrary to the above, from February 19, 2016, until March 16, 2018, the licensee failed to perform a required analysis using the methodology in Chapter 2 of NFPA 805 for the RHRSW piping as a result of a postulated fire scenario. Specifically, the licensee’s nuclear safety performance criteria analysis did not evaluate the fire induced failure mode of spurious opening of the RHRSW outlet valves and subsequent voiding of piping which provided the increased likelihood of a water-hammer event.

Significance: Using IMC 0609 Appendix F, the violation was screened to Green because the licensee was able to prove that the RHRSW piping would remain functional following a postulated water-hammer event.

Corrective Action Reference(s): Condition Reports (CR) 1139620 and 1397087

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This violation closes AV 05000259, 260, 296/2018002-03 Failure to Analyze for a Water Hammer Event due to Spurious Operation of Residual Heat Removal Service Water (RHRSW) Valves During a Fire Event.

Main Steam Relief Valves Lift Settings Outside of Technical Specifications Required Setpoints Cornerstone Severity Cross-cutting

Aspect Report Section

Not Applicable Severity Level IV NCV 05000296/2018-003-01 Closed

Not applicable 71153

A self-revealed SL IV NCV of TS 3.4.3 was identified when the licensee discovered, through as found test results, that three of the thirteen 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. Description: 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. Corrective Action(s): The licensee replaced all thirteen of the Unit 3 MSRV pilot valves with refurbished valves during the Spring 2018 Unit 3 refueling outage. The licensee has corrective actions in place to ensure that pilot discs are prepared for platinum coating in accordance with the revised procedure and vendor recommendations. The currently installed valves were certified, tested and as-left values were verified to be within +/- 1 percent of their setpoints, and had platinum coating in accordance with the updated procedure.

Corrective Action Reference(s): CRs 962223, 1252419, and 1416743

Performance Assessment: Traditional Enforcement Assessment: The inspectors determined that because the licensee received the refurbished valves after being inspected, certified and tested to within +/- 1 percent of their setpoint values, the issue could not be reasonably foreseeable and preventable. Inspectors concluded that no performance deficiency exists. The licensee is aware of the industry issues of corrosion bonding and platinum coating flaking associated with these types of valves. These issues are documented and actions are being taken through their corrective action program to improve the coating process.

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Enforcement: Severity: Traditional Enforcement is being used because there was no performance deficiency using the Interim Guidance for Dispositioning Severity Level IV Violations with No Associated Performance Deficiency (ML18158A220). This violation is characterized as a Severity Level IV NCV based on its similarity to a SLIV example 6.1.d.1 in the Enforcement Policy.

Violation: Browns Ferry Nuclear Plant, Unit 3 TS Subsection 3.4.3, ‘Safety/Relief Valves (S/RVs),’ Condition A, required that with one or more required S/RVs inoperable, that the unit be in Mode 3 in 12 hours and Mode 4 in 36 hours. Contrary to the above, two required S/RVs were inoperable from March 26, 2016, to February 17, 2018, and the unit did not enter Mode 3 and Mode 4 in 12 hours and 36 hours, respectively.

Enforcement Action(s): This violation is being treated as an 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. • On October 19, 2018, the quarterly resident inspector inspection results were presented to

Lang Hughes and other members of the licensee staff.

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DOCUMENTS REVIEWED IP 71111.01 Procedures 0-AOI-100-3, Flood Above Elevation 558’, Revision 46 MPS-0-000-INS001 Inspection of Flood Protection Devices, Revision 17 IP 71111.04 Procedures 0-GOI-300-1/ATT-5, Unit 1 Reactor Building Operator Round Logs, Revision 260 1-OI-73, High Pressure Coolant Injection System, Revision 30 3-OI-71, Reactor Core Isolation Cooling System, Revision 58 Drawings 1-47E812-1, Flow Diagram High Pressure Coolant Injection, Revision 46 1-47E812-2, Flow Diagram HPCI Oil System, Revision 5 47W450-6, Unit 2 Mechanical RHR Service Water Isometric Drawing, Revision 3 2-47E450-2, Unit 2 Mechanical RHR Service Water Piping, Revision 9 3-47E813-1, Flow Diagram Reactor Core Isolation Cooling System, Revision 52 Other Documents CR 374844 WO 112291048 CR 1139620 ANSYS Functional Assessment of the Residual Heat Removal Service Water (RHRSW) Water Hammer Event dated August 22, 2018 NUREG 0927 Evaluation of Water Hammer Occurrence in Nuclear Power Plants, Revision 1 Generic Letter 96-06 Water Hammer Issues Resolution EPRI Technical Basis Report 113594 “Resolution of Generic Letter 96-06 Waterhammer Issues” WO 118350502 IP 71111.05 Procedures FPR-Volume 2, Fire Protection Report Volume 2, Revision 60 0-FSS-16-1, Control Building EL 593', 606', 617' and 635', Revision 10 3-FSS-16-2, Unit 3 Abandonment Control Building EL 593', 606', 617' and 635', Revision 9 0-FSS-18, U-2 Battery and Battery Board Room Control Building EL 593’, Revision 5 Other Documents NFPA 805 Fire Protection Requirements Manual, Revision 6 EDQ099920110010, NFPA 805 – Nuclear Safety Capability Analysis, Revision 45 Drawings 3-47E216-71, NFPA 805 Fire Areas Plan EL 606.0, 617.0 and 621.0, Revision 0 3-47E216-68, NFPA 805 Physical Analysis Units Plan EL. 565.0 and 593.0, Revision 0 0-47E216-69, NFPA 805 Fire Areas Plan EL. 593.0 and 586.0, Revision 0

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IP 71111.06 Other Documents CR 1342280 DED-TM-PF2, Concluding Report on the Effects of Postulated Pipe Failure Outside of Containment for the Browns Ferry Nuclear Plant Units 2 and 3 NDN-000-999-2007-0031, BFN Probabilistic Risk Assessment - Internal Flooding Analysis, Revision 1 IP 71111.07 Procedures 0-TI-246, Inspection of Ponds, Dikes, and Channels, Revision 3 Other Documents CR 1392561 PDO for CR 1392561 CR 1389291 CR 1376948 FSAR Section 2.4 FSAR Appendix O.1.33 PM 500102982, BFN Ponds, Dikes, and Channels CDQ0003602015000308, Sunny Day Loss of Wheeler Dam, Revision 1 WO 112230706 WO 119432213 WO 114229262 WO 119723184 2014 Intake Channel Surveys Drawings 0-37W400-2, Mechanical Auxiliary Raw Cooling Water Piping, Revision 0 0-31E201, Concrete General Outline Features Sheet 1, Revision 2 67 C 4 10N214 RD, Finished Grading Plan Intake Structure and Channel IP 71111.11 Procedures NPG-SPP-17.8.4, Conduct of Simulator Operations, Revision 5 3-TI-380, Power Ascension Turbine Valve Test, Revision 3 3-TI-700, EPU Master Startup Test Instruction, Revision 14 3-TI-701, EPU Vibration Monitoring, Revision 6 Other Documents OPL175S051, ATWS DLA, Revision 0 OPL175S269, Low EDG Battery Voltage, Failed MSIV, Lowering Main Condenser Vacuum, Revision 0 Simulator Exam Exam 75, LOR-Exam-75 (E1), Rev 1 Exam 74, LOR-Exam-74 (E2), Rev 1 Exam 60, LOR-Exam-60 (A1), Rev 2 Exam 61A, LOR-Exam-61A (A2), Rev 2

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Written Exam Exam #4, 2017 Biennial Written Exam #4 Exam #1, 2017 Biennial Written Exam #1

JPMs JPM 718, Loss of RPV Inventory, Rev 0 JPM 355 U3, Emergency Venting Primary Containment, Rev 3 JPM 18A, RCIC Injection IAW Appendix 5C, Rev 7 JPM 345 U3, Alternate RPV Pressure Control using HPCI, Rev 1 JPM 324, Bypassing RCIC Isolation Interlocks, Rev 6 JPM FSS08F, Start RHR 2C per 2-FSS-16-2, Rev 0 JPM FSS20, Align Battery Charger 2B to Battery Board 3 per 0-FSS-22, Rev 0 JPM FSS22, Align RMOV loads per 0-FSS-05, Rev 0 JPM FSS06, Align U1 CAS Logic Switches per 0-FSS-2-1, Rev 0 JPM 717, Emergency Plan – Damage to Irradiated Fuel, Rev 0 JPM 713, Load Shed of Main Battery Bank, Rev 0 JPM 711, Bypassing RCIC High Temperature Isolations, Rev 0 JPM 277AP U3, RR Pump Shutdown (not in Mode 1), Rev 2 JPM 141AP U2, Restore RPV water level using RCIC, Rev 1 Procedures NPG-SPP-17.8.1, Licensed Operator Requalification Examination Development and Implementation, Rev 16 NPG-SPP-17.8.2, Job Performance Measures Development, Administration, and Evaluation, Rev 4 NPG-SPP-17.8.3, Simulator Exercise Guide Development and Revision, Rev 8 NPG-SPP-17.8.4, Conduct of Simulator Operations, Rev 4 NPG-SPP-17.4.1, Exam Security and Exam Database Management Rev 9

Medical Records 17 Reviewed

Reactivation Records 2 Reviewed Training Records HPCI JITT, 5/1/17 U3 Startup JITT following refueling outage, 3/20/18 U2 Startup JITT following refueling outage, 2/22/17 U3 Hydro JITT, 10/18/17 Post SCRAM startup JITT, 3/21/18 Cycle 1801 attendance records Cycle 1802 attendance records 2017 Biennial written exam attendance records

Remedial Records 2017 Biennial written exam failure 2018 Biennial scenario remediation for one crew (non-failure) 2 records – Cycle written exam failures 2018 Biennial scenario remediation for two crews (failure)

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Simulator Problem Reports 5717 (Closed), Plant/Simulator Discrepancy, 10/11/17 5681 (Open), FW Heater Extraction and Non-return Valves Incorrectly Modelled, 12/13/16 Performance Tests TRN-12, 75% Steady State Test – Unit 2, September 8, 2017 TRN-12, Simultaneous Trip of all Recirc Pumps – Unit 2, October 23, 2017 TRN-12, MSIV Isolation and Relief Valve Failure – Unit 2, October 23, 2017 TRN-12, Manual Rate Power Ramp – Unit 2, October 23, 2017 TRN-12, Coolant Leak Inside Drywell (TH22) – Unit 2, November 20, 2016 TRN-12, Loss of 250V Battery Board 3 (ED17) – Unit 2, November 11, 2016 TRN-12, Condensate Pump Trip (FW01) – Unit 2, August 22, 2017 0-SR-3.8.1(A), Diesel Generator A Monthly Operability Test – Unit 2, September 30, 2017 0-SI-4.2B-67, RHR Service Water Initiation Logic – Unit 2, September 30, 2017 NPG-SPP-17.8.5, 40% Steady State Test – Unit 3, April 16, 2018 NPG-SPP-17.8.5, Simultaneous Trip of all Feedwater Pumps – Unit 3, February 14, 2018 NPG-SPP-17.8.5, Turbine Trip < 30% Power – Unit 3, February 14, 2018 NPG-SPP-17.8.5, Drift Any Control Rod Out (RD04) – Unit 3, April 20, 2018 NPG-SPP-17.8.5, Generator Lockout (286A, B, C) Due to Transformer Faults (EG01A) – Unit 3, March 2, 2018 Condition Reports CR 1323187, Crew Failure following As-found Scenario CR 1399780, HPCI Discharge valve discovered closed during PMT run CR 1392661, Clearance Error, A CR 1389893, 3B CS Pump inadvertent start CR 1287160, Diesel Mode switch inadvertent switch placement CR 1391380, B2 RHRSW inadvertent trip N/A CR 1446873, U2 Simulator Inadvertent Freeze During an Annual Operating Exam JPM

Self-Assessment BFN-TRN-FSA-18-002, Pre-IP 71111.11 NRC Inspection Self-Assessment, 5/21-25/18 IP 71111.12 Procedures NPG-SPP 09.18.2 Equipment Reliability Classification and Maintenance Strategy Development, Revision 003 NPG-SPP 09.16.1 System, Component and Program Health, Revision 0011 0-TI-362 Inservice Testing Program, Revision 0055 0-TI-362 IST Program Bases Document, Revision 0014 Other Documents DCN 72221 Alternate Leakage Path Modification for 3-FCV-1-185 Main Steam System Health Report dated May 7, 2018 Main Steam System Alternate Leakage Path Boundary Function 001C-E (a)(1) Plan, Revision 10 CR 1410787 Browns Ferry Nuclear Plant Units 1, 2, and 3 Maintenance Rule 11th Periodic Report, Revision 0

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IP 71111.13 Procedures: BFN-ODM-4.18 Protected Equipment, Revision 20 NPG-SPP-09.11.1, Equipment Out of Service Management, Revision 12 NPG-SPP-07.3.4 Protected Equipment, Revision 4 3-SR-3.8.4.3(MB-3), Main Bank 3 Battery Service Test, Revision 12 MSI-0-000-LFT001, Lifting Instructions for the Control of Heavy Loads, Revision 74 Other Documents: CR 1434149 WO 119380859 IP 71111.15 Procedures: OPDP-8, Operability Determination Process and Limiting Conditions for Operation Tracking, Revision 24 0-TI-403, Common Cause Failure Evaluation for Emergency Diesel Generators, Revision 2 NPG-SPP-22.300, Corrective Action Program, Revision 10 3-SI-4.7.A.2.g-3/3A, Primary Containment Local Leak Rate Test Reactor Feedwater Line A: Penetration X-9A, Revision 15 ECI-0-000-LUG001, Electrical Corrective Instruction, Revision 39 EII-0-000-TCC106, Troubleshooting, Documentation and Configuration Control of Electrical Activities, Revision 51 TPP-0-000-LUG0001, Requirements, Limitations and Tables for Lugging, Splicing and Terminating Cables, Revision 1 2-SR-3.3.1.1.8(5), MSIV Closure – RPS Trip Channel Functional Test, Revision 18 Drawings: 3-47E801-1-ISI, ASME Section XI Flow Diagram Main Steam Code Class Boundaries, Revision 22 2-47E610-1-1, Mechanical Control Diagram Main Steam System, Revision 38 2-730E915-9, Elementary Diagram Reactor Protection System, Revision 25 2-730E915-10, Elementary Diagram Reactor Protection System, Revision 27 2-730E915RF-11, Elementary Diagram Reactor Protection System, Revision 14 2-730E915-1, Elementary Diagram Reactor Protection System, Revision 23 1-47E854-1, Flow Diagram Standby Liquid Control System, Revision 17 Other Documents: CR 1429944 Common Cause Evaluation Form for CR 1429944 CR 1431344 Common Cause Evaluation Form for CR 1431344 CR 1391831 CR 1398557 CR 1442623 PDO for CR 1442623 WO119831521 to calibrate 2-PIS-68-95 DCN 71861 WO 119425090 CR 1432867 CR 1432558

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WO 1197744453 Functionality Evaluation Documentation for CR 1435680 CR 1435134 CR 1435135 WO 119785907 WO 119607692 EQ Binder BFN0EQ-SPLC-001 H1 CR 1449196 CR 1439832 Calculation MDQ0063900083, Revision 8 IP 71111.18 Procedures DCN 71861 Replacement of Weed DTN2010 transmitter to Weed DTN2070 Transmitter, Revision A DCN 68744 Replace the existing obsolete Tobar EQ transmitters with similar devices, Revision A DCN 71582 NFPA 805 Issue 35A Supplemental Diesel Generator, Stage2 and Stage 3 0-OI-83 Supplemental Diesel Generator System, Revision 2 Drawings 3-45E670-27, Wiring Diagram ECCS DIV I Analog Trip Units, Revision 2 0-45N802-20, Conduit and Grounding Elevation 565.0’, Revision 1 3-47E600-60, Mechanical Instrument and Controls, Revision 4 0-45E763-2, Wiring Diagram 4160v Unit Aux Power Schematic Diagram, Revision 44 Documents Ultra Electronics Information Pamphlet for Weed Model DTN2070 Differential Pressure Transmitter, dated October 2014 WO 118091248 WO 118091249 CR 1415013 CR 1402958 IP 71111.19 Procedures 0-PMTI-82-1 (DG D), WO 119021820 PMT Diesel Generator D 2301A and DRU Setup and Tuning Instruction, Revision 1 0-PMTI-82-2 (DG D), WO 119021820 PMT Diesel Generator D Monthly Operability Test with Large Load Reject, Revision 0 **CONTINGENCY** Replace Diesel Tie Breaker Handswitch 3-HS-211-03EA/09A, WO 119158559, Revision 0 3-SR-3.8.1.1(3A) – Diesel Generator 3A Monthly Operability Test, WO 118573287, Revision 0 3A DG tripped on Differential Overcurrent during an attempt to parallel with offsite power, WO 119768067, Revision 0 2-SR-3.3.5.1.4(C) – Core and Containment Cooling Systems Reactor Low Pressure Instrument Channel C Calibration 2-P-68-95, Revision 9 3-TI-130, Main Steam Pressure Control, Revision 3 3-TI-131, Feedwater Level Control System, Revision 6 3-TI-700, EPU Master Startup Test Instruction, Revision 14 3-TI-701, EPU Vibration Monitoring, Revision 6

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Other Documents CR 1429944 CR 1431601 CR 1431344 CR 1434973 CR 1442623 WO 119831524 Browns Ferry Updated Final Safety Analysis Report, Sections 6.4 and 7.4, Amendment 27 WO 119831521 WO 119840596 CR 1422410 CR 1428010 CR 1422408 Unit 3 Test Data from 3-TI-130 and 3-TI-131 IP 71111.22 Procedures 1-SR-3.5.1.1(HPCI), Maintenance of Filled HPCI Discharge Piping, Revision 9 0-SR-3.8.1.1(B) Diesel Generator B Monthly Operability Test, Revision 66 3-SR-3.8.4.3 (MB-3) Main Bank 3 Battery Service Test, Revision 12 ECI-0-000-MOV009 Testing of Motor Operated Valves, Revision 46 1-SI-4.4.A.1 Standby Liquid Control Pump Function Test, Revision 27 2-SR-3.5.1.7(COMP) HPCI Comprehensive Pump Test, Revision 30 Other Documents WO 118568689 WO 118569612 CR 164399, 142923, 229022, 1369055, 1027287, 1392973, 1447136, 1447180 MDQ0000732012000062, Calculation of Effects of Gas Accumulation in ECCS Piping, Revision 0 WO 118836977 71114.06 - Drill Evaluation Procedures EPIP-1, Emergency Classification Procedure, Revision 56 Other Documents 2018 BFN July 11 Training Drill Package 2018 BFN August 1 Training Drill Package IP 71151 Procedures NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7 Browns Ferry Nuclear Plant, Unit 1 MSPI Basis Document, Revision 18, dated September 30, 2016 Browns Ferry Nuclear Plant, Unit 2 MSPI Basis Document, Revision 17, dated September 30, 2016 Browns Ferry Nuclear Plant, Unit 3 MSPI Basis Document, Revision 16, dated September 30, 2016

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Other Documents Units 1, 2, and 3 inputs for Cooling Water MSPI Units 1, 2, and 3 logs from July 1, 2017 until June 30, 2018. Units 1, 2, and 3 inputs for Emergency AC Power MSPI CR 1389131 IP 71152 Drawings 47W450-6, Unit 2 Mechanical RHR Service Water Isometric Drawing, Revision 3 2-47E450-2, Unit 2 Mechanical RHR Service Water Piping, Revision 9 Other Documents CR 1139620 ANSYS Functional Assessment of the Residual Heat Removal Service Water (RHRSW) Water Hammer Event dated August 22, 2018 NUREG 0927 Evaluation of Water Hammer Occurrence in Nuclear Power Plants, Revision 1 Generic Letter 96-06 Water Hammer Issues Resolution EPRI Technical Basis Report 113594 “Resolution of Generic Letter 96-06 Waterhammer Issues” IP 71153 Procedures Emergency Plan Implementing Procedure (EPIP)-1, Emergency Classification Procedure, Revision 56 Fire Protection Report-Volume 2, Revision 60 MCI-0-001-VLV002, Main Steam Relief Valves Target Rock Model 7576 Disassembly. Inspection, Repair and Reassembly, Revisions 50 and 51 Other Documents CR 1441631 CR 1441627 CR 1441620 CR 962223 CR 1252419 CR 1320605 CR 1286467 CR 1416473 CR 1389131 CR 1389133 CR 1390278 CR 803629 3C Diesel Generator Load Acceptance Test Failure, Level 1 Evaluation (RCA) Report, Rev 0 IP 60855 Procedures MSI-0-000-LFT001, Lifting Instructions for the Control of Heavy Loads, Rev. 74 MSI-0-079-DCS300.9, Helium Backfill System Operation (HI-STORM 100 System), Rev. 5 MSI-0-079-DCS400.1FW, ISFSI Abnormal Conditions Procedure Placing the MPC-89 in a Safe Condition, Rev. 5 MSI-0-079-DCS200.2, MPC-68 Loading and Transport Operations, Rev. 31 RWI-001, Administration of the Radioactive Material and Radwaste Packaging and Transportation Program, Rev. 12