ML101040455
| ML101040455 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/14/2010 |
| From: | Jeff Circle, Gerald Gulla Office of Nuclear Reactor Regulation, NRC/OE |
| To: | |
| Gulla G. 415-2872 | |
| References | |
| EA-09-307 EN-10-018 | |
| Download: ML101040455 (3) | |
Text
April 14, 2010 EN 10-018 OFFICE OF ENFORCEMENT NOTIFICATION OF SIGNIFICANT ENFORCEMENT ACTION Licensee: Tennessee Valley Authority EA-09-307 Browns Ferry 1, 2, and 3 Docket No. 50-259, 260, 296
Subject:
ISSUANCE OF FINAL SIGNIFICANCE DETERMINATION AND NOTICE OF VIOLATION This is to inform the Commission that one Yellow and one White Significance Determination Process (SDP) finding will be issued on or about April 19, 2010, to Tennessee Valley Authority (TVA; licensee), as a result of inspections at Browns Ferry 1, 2, and 3. These findings will require additional inspections on all three units. The Yellow finding involves multiple examples, in all three units, of failures to satisfy requirements of 10 CFR Part 50, Appendix R, Sections III.G.1 and III.G.2, which involve fire protection for safe shutdown capability. The White finding involves an inappropriate revision to the Browns Ferry Post-Fire Safe Shutdown Instruction entry conditions.
As a result of this revision, the safe shutdown instruction may not have been entered for use which could have delayed proper operator response to a major disabling fire event.
At the request of the licensee a Regulatory Conference was held on February 22, 2010, to discuss the risk significance of the findings. After reviewing the information developed during the inspection and the supplemental information provided by the licensee during the conference, the staff concluded that the inspection findings are appropriately characterized as Yellow and White.
The NRC determined that these findings do not present an immediate safety concern. For the Yellow finding, the licensee implemented compensatory measures while long-term corrective actions are being addressed, which include transitioning to the National Fire Protection Association (NFPA) Standard 805. The compensatory measures consist of operator manual actions to mitigate or prevent damage to equipment necessary for safe shutdown in the event of a fire. The staff reviewed the critical operator manual actions and concluded that they were feasible. The licensee also implemented additional fire watches for all three units. The second finding has been corrected by a revised safe shutdown instruction.
Two violations will be issued.
The first violation is based on a violation of 10 CFR Part 50, Appendix R, Section III.G, which addresses fire protection for safe shutdown capacity. The staff first identified this issue in 2006 and has documented it as several unresolved items in inspection reports. The violation is being dispositioned at this time due to the expiration (March 6, 2009) of enforcement discretion1. The licensee has been in violation of this regulation since the restart of each unit (Unit 2-1991, Unit 3-1995, Unit 1-2007) and as of January 20, 2010, the date of the inspection report, the licensee continues to fail to meet the requirements of 10 CFR Part 50, Appendix R, Section III.G, in that:
1 Enforcement discretion for this existing identified noncompliance under National Fire Protection Association Standard 805 (NFPA 805) did not apply since the licensee submitted their letter of intent and started their transition process after December 31, 2005 as required by the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues in order to receive the discretion.
- 1) TVA failed to provide fire protection features capable of limiting the fire damage such that one train of systems necessary to achieve and maintain hot shutdown conditions would remain free from fire damage in Fire Area 8 along with 19 other fire areas designated in the Browns Ferry Fire Protection Report in accordance with 10 CFR Part 50, Appendix R, Section III.G.I.
- 2) TVA failed to ensure that one train of cables of redundant systems or equipment, located in the same fire area, necessary to achieve and maintain hot shutdown conditions for the RHRSW Pump A1, RHR Pump 1A, and LPCI injection valve 1-FCV-74-53 in Fire Area 1/Fire Zone 1-4 (including multiple examples in other fire areas) would remain free of fire damage by one of the means described in 10 CFR Part 50, Appendix R, Section III.G.2.
This violation is associated with the Yellow significance determination process finding for Units 1, 2, and 3 in the Mitigating Systems cornerstone.
The second violation is based on a violation of a Technical Specification. The licensee revised the entry conditions of their "Safe Shutdown Instructions" which added a non-conservative reactor vessel water level entry condition. This would have delayed or prevented establishment of safe shutdown conditions during a postulated major fire event.
This violation is associated with the White significance determination process finding for Units 1, 2, and 3 in the Mitigating Systems cornerstone.
It should be noted that the licensee has not been specifically informed of the enforcement action.
The schedule of issuance and notification is:
Mailing of Final Significance Determination April 19, 2010 Telephone Notification of Licensee April 19, 2010 The State of Alabama will be notified.
Contacts: Jeff Circle, NRR SRA, (301) 415-1152 Gerry Gulla, OE, (301) 415-2872
Distribution: EN-10-018, April 14, 2010 OWFN OWFN TWFN EBB Regional Offices Chairman Jaczko EDO OCFO NMSS RI RII Comm. Svinicki DEDR OP CENTER RIII RIV Comm. Apostolakis DEDMRS FSME Comm. Magwood OE OIG MAIL Comm. Ostendorff OGC OCIO ADAMS SECY NRR RES OE staff OCA NSIR ACRS PA OI IP Electronic DISTRIBUTION:
R. Zimmerman, OE N. Hilton, OE G. Gulla, OE J. Circle, NRR OE r/f EN binder ML101040455 X PUBLIC X NON-SENSITIVE OFFICE OE:ES OE:BC NAME G. Gulla N. Hilton DATE 04/09/10 04/09/10 OFFICIAL RECORD COPY