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NRC Confirmatory Order EA-14-005 - Completion of Actions
	ML16006A126
Person / Time
Site:	Browns Ferry
Issue date:	01/05/2016
From:	James Shea; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	CNL-15-251, EA-14-005
	Download: ML16006A126 (3)
	v • d • e

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-15-251 January 5, 2016 10 CFR 50.4 ATTN : Document Control Desk U.S. Nuclear Regulatory Commission Washington , D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, DPR-68 NRC Docket Nos. 50-259, 50-260, 50-296

Subject:

NRC Confirmatory Order EA-14-005 - Completion of Actions Reference : Confirmatory Order (NRC Inspection Report 05000259/2013005, 05000260/2013005, and 05000296/2013005), dated May 1, 2014 The above referenced Confirmatory Order from the Nuclear Regulatory Commission (NRC) to Tennessee Valley Authority (TVA) details 20 TVA fleet and Browns Ferry Nuclear Plant (BFN)-specific actions related to the violation of Title 10 of the Code of Federal Regulations (CFR) 50.9, Completeness and Accuracy of Information , and related to the violation of 10 CFR 50.90, Application for Amendment of License , Construction Permit, or Early Site Permit.

The purpose of this letter is to provide TVA's basis for concluding that the Order has been satisfied. TVA entered the Confirmatory Order actions into the corrective action program as condition reports (CRs) and completed the associated CR cause analyses, corrective and preventative actions, enhancements, and effectiveness reviews. Based on the completion of these activities, TVA has determined that the Confirmatory Order has been satisfied. A summary of the actions taken is provided below.

The actions related to the violation of 10 CFR 50.9 required by the Confirmatory Order have been completed and included:

1) Fleet actions to develop and implement a fleet-wide procedure governing the preparation of information intended to support licensing submittals to the NRC; and,

2) BFN-specific actions to:

a. Implement an Integrated Completeness and Accuracy Review Evaluation Board to provide pre-submittal reviews of correspond ence and supporting documentation for BFN submittals to the NRC; and,

b. Benchmark industry best practices in the area of 10 CFR 50.9 compliance in the preparation and validation of NRC submittals.

U.S. Nuclear Regulatory Commission CNL-15-251 Page 3 January 5, 2016 The actions related to the violation of 10 CFR 50.90 required by the Confirmatory Order have been completed and included :

1) Fleet actions to :

a. Benchmark industry methodologies used to maintain Licensing Bases Documents for incorporation consideration ;

b. Develop and implement a fleet-wide Licensing Compliance Review procedure ,

including incorporation of the new procedure into existing procedures governing procedure adm inistration;

c. Revise the TVA Nuclear Power Group administrative and techn ical procedures to incorporate the new Licensing Compliance Review procedure; and ,

d. Convert the Final Safety Analysis Report Management procedure from a department-level procedure to a nuclear fleet-level procedure.

2) BFN-specific actions to :

a. Perform a snapshot self-assessment to verify if commitments are being implemented accurately;

b. Close the Corrective Action Program Fundamental Problem identified as part of TVA's response to the 2013 NRC Inspection Procedure 95003 inspection ;

c. Implement interim actions until the Licensing Compliance Review procedure became active;

d. Perform detailed reviews of Procedure Upgrade Project procedure revisions to ensure licensing basis information is identified ;

e. Train Engineering , Licensing , and Licensed Operators regarding scope and hierarchy of licensing basis documents and lessons learned from EA-14-005;

f. Implement the utilization of a second reviewer for commitments ;

g. Review a sample of facility changes within the last ten years , based on risk and complexity , to determine whether the changes were appropriately incorporated into the licensing basis documents;

h. Review a sample of facility changes within the last three years and outside the 10 CFR 50.59 process, based on risk and complexity, to determine whether the changes were appropriately incorporated into the licensing basis documents; and ,

i. Make a presentation to the Regulatory Issue Working Group and the Regulatory Utility Group regarding the circumstances of these violations and the importance of effective management of the current licensing basis and complete and accurate communications with the NRC .

The Order also required several independent reviews , which have been completed :

1) An independent entity assessment of the completeness and adequacy of the 10 CFR 50.9 and 10 CFR 50.90 Root Cause Analysis reports to assess the completeness and adequacy of the root/contributing causes , extent of cause , extent of condition , and corrective actions to prevent recu rrence/corrective actions with consideration of assessment recommendations for implementation;

2) An independent effectiveness review of the 10 CFR 50.9 and 10 CFR 50.90 Root Cause Analyses corrective actions; and,

3) An independent reevaluation of Operations minimum shift staffing .

U.S. Nuclear Regulatory Commission CNL-15-251 Page 3 January 5, 2016 With the submittal of this letter, all actions required by NRC Confirmatory Order EA-14-005 have been completed . There are no new regulatory commitments contained in this letter. If you have any questions regarding this response , please contact J. L. Pau l, BFN Nuclear Site Licensing Manager, at (256) 729-2636.

cc: NRC Regional Administrato r- Region II NRC Senior Resident Inspector- Browns Ferry Nuclear Plant