ML101690081
| ML101690081 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/17/2010 |
| From: | Kennedy K Division of Reactor Safety II |
| To: | Krich R Tennessee Valley Authority |
| References | |
| EA-09-307 | |
| Download: ML101690081 (4) | |
See also: IR 05000259/2010007
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200
ATLANTA, GEORGIA 30303-1257
June 17, 2010
Mr. R. M. Krich
Vice President, Nuclear Licensing
Tennessee Valley Authority
3R Lookout Place
1101 Market Street
Chattanooga, TN 37402-2801
SUBJECT:
REPLY TO TENNESSEE VALLEY AUTHORITY LETTER DATED MAY 18,
2010, REGARDING INSPECTION REPORT NO. 05000259/2010007,
05000260/2010007, AND 05000296/2010007, BROWNS FERRY NUCLEAR
PLANT
Dear Mr. Krich:
Thank you for your letter dated May 18, 2010, from Mr. K.J. Polson, Browns Ferry Site Vice
President, in response to our Notice of Violation (EA-09-307) dated April 19, 2010. The Notice
of Violation described two violations that were identified during an inspection conducted by the
Nuclear Regulatory Commission (NRC). The first violation involved multiple examples of failure
to satisfy the requirements of 10 CFR Part 50, Appendix R, Sections III.G.1 and III.G.2. The
second violation involved an inappropriate revision to the Browns Ferry post-fire safe shutdown
instruction entry conditions, which resulted in the safe shutdown instruction not meeting the
requirements of Technical Specification 5.4.1.
With regard to the first violation, we understand that full compliance with the requirements of
10 CFR 50.48(c), without relying on compensatory measures, will be achieved upon completing
the implementation of the transition to National Fire Protection Association (NFPA) 805,
Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating
Plants 2001 Edition. You further stated that the Tennessee Valley Authority (TVA) plans to
initiate fire protection program improvements prior to completion of the transition to NFPA 805,
and plans to prioritize these improvements based on those with greater impact on overall fire
risk reduction. We understand that you have implemented compensatory measures, in
accordance with your fire protection program, to address all non-compliances with 10 CFR Part
50, Appendix R, Sections III.G.1 and III.G.2. These compensatory measures, which include fire
watches and operator manual actions, will remain in effect until full compliance with the
regulation is achieved. In addition, you stated that you have evaluated the most critical operator
manual actions and revised safe shutdown instructions to include independent confirmation of
2
actions, to improve the likelihood of success. To further reduce the risk associated with this
violation, you have posted fire watches as additional compensatory measures.
The current enforcement discretion policy provides for up to 3 years of discretion during your
transition to NFPA 805. In a letter dated March 4, 2009, TVA stated its intent to adopt NFPA
805, as the licensing basis for the Browns Ferry fire protection program. Therefore, the staff
anticipates that you will submit your license amendment request by March 4, 2012. After
reviewing your license amendment request, if the NRC approves your request in a safety
evaluation report, the NRC will include a license condition identifying the date by which you
must complete the transition by performing the appropriate plant changes (e.g., changes to fire
protection procedures to comply with 10 CFR 50.48(c)). The date by which you are required to
complete your transition will be based on the nature of changes that you plan to implement. By
that date, you will be required to comply with your fire protection program without relying on any
long-term compensatory measures.
Based on corrective actions taken to date, your docketed intention to transition your fire
protection licensing basis to NFPA 805, and the enforcement discretion policy, as well as dates
that NRC plans to impose on you via a license condition in the safety evaluation report, we find
that your response to the Notice of Violation meets the intent of 10 CFR 2.201 with respect to
providing a date for obtaining full compliance.
We have reviewed your response to the second violation (Technical Specification 5.4.1), and
find that that it meets the requirements of 10 CFR 2.201. In your response you stated that full
compliance was achieved when you restored the entry conditions to those which were in place
prior to the revision. You also described additional actions you plan to take to address the
reasons this violation occurred.
We will review the adequacy and status of your corrective actions during a supplemental
inspection utilizing NRC Inspection Procedure 95002, once you have indicated you are ready for
this inspection. In addition, we will monitor your progress in transitioning your fire protection
licensing basis to NFPA 805, through routine baseline inspections, including the resident and
triennial fire protection inspections. In accordance with 10 CFR 2.390 of the NRCs Rules of
Practice, a copy of this letter will be made available electronically for public inspection in the
NRC Public Document Room or from the NRCs document system (ADAMS), accessible from
the Web site at http://www.nrc.gov/reading-rm/adams.html.
Sincerely,
/RA/
Kriss M. Kennedy, Director
Division of Reactor Safety
Docket Nos.: 50-259, 50-260, 50-296
License Nos.: DPR-33, DPR-52, DPR-68
cc: See page 3
3
cc:
K. J. Polson
Vice President
Browns Ferry Nuclear Plant
Tennessee Valley Authority
P.O. Box 2000
Decatur, AL 35609
J.J. Randich
General Manager
Browns Ferry Nuclear Plant
Tennessee Valley Authority
P.O. Box 2000
Decatur, AL 35609
F.R. Godwin
Manager, Licensing and Industry Affairs
Browns Ferry Nuclear Plant
Tennessee Valley Authority
P.O. Box 2000
Decatur, AL 35609
E. J. Vigluicci
Assistant General Counsel
Tennessee Valley Authority
6A West Tower
400 West Summit Hill Drive
Knoxville, TN 37902
State Health Officer
Alabama Dept. of Public Health
RSA Tower - Administration
Suite 1552
P.O. Box 30317
Montgomery, AL 36130-3017
Chairman
Limestone County Commission
310 West Washington Street
Athens, AL 35611
James L. McNees, CHP
Director
Office of Radiation Control
Alabama Dept. of Public Health
P. O. Box 303017
Montgomery, AL 36130-3017
Senior Resident Inspector
U.S. Nuclear Regulatory Commission
Browns Ferry Nuclear Plant
U.S. Nuclear Regulatory Commission
10833 Shaw Road
Athens, AL 35611-6970
_________________________
G SUNSI REVIEW COMPLETE
OFFICE
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SIGNATURE
RA VIA EMAIL
NAME
MTHOMAS
RNEASE
CEVANS
KKENNEDY
DATE
6/17/2010
6/17/2010
6/17/2010
6/17/2010
E-MAIL COPY?
YES
NO YES
NO YES
NO YES
NO YES
NO YES
NO YES
NO