ML12054A688

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Reply to Notice of Violation; EA-11-252
ML12054A688
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 02/22/2012
From: James Shea
Tennessee Valley Authority
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-11-252, IR-11-011, IR-12-010
Download: ML12054A688 (7)
v • d • e


Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 February 22, 2012 10 CFR 2.201 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296

Subject:

Reply to Notice of Violation; EA-1 1-252

References:

1. Letter from NRC to TVA, "Browns Ferry Nuclear Plant - NRC Inspection Procedure 95003 Supplemental Inspection Report 05000259/2011011, 05000260/2011011, and 05000296/2011011 (Part 1)," dated November 17, 2011
2. Letter from TVA to NRC, "Response to an Apparent Violation in Inspection Report 05000259/2011011, 05000260/2011011, 05000296/2011011; EA 252," dated December 19, 2011
3. Letter from NRC to TVA, "Browns Ferry Nuclear Plant - Notice of Violation NRC Inspection Report 05000259/2012010, 05000260/2012010, and 05000296/2012010," dated January 23, 2012 In accordance with the NRC letter dated November 17, 2011 (Reference 1), the Tennessee Valley Authority (TVA) submitted a response to Apparent Violation EA-1 1-252 (Reference 2).

Subsequently, NRC issued Notice of Violation EA-1 1-252 on January 23, 2012 (Reference 3).

In accordance with the Reference 3 letter, TVA is required to respond to the Notice of Violation within 30 days of the date of the letter (i.e., February 22, 2012). The TVA response to this notice of violation, including information regarding extent of condition reviews, is provided in the enclosure in accordance with 10 CFR 2.201, "Notice of violation."

ii._,

U.S. Nuclear Regulatory Commission Page 2 February 22, 2012 There are no new regulatory commitments contained in this response. Should you have any questions concerning this submittal, please contact James Emens at (256) 729-2636.

Resp t Ily,

  • . hea nager, Corporate Nuclear Licensing

Enclosure:

Reply to Notice of Violation; EA-1 1-252 cc (Enclosure):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant

ENCLOSURE Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Reply to Notice of Violation; EA-11-252

Reply to Notice of Violation; EA-11-252 Restatement of Violation 10 CFR 50.9 requires, in part, that information provided to the Commission by an applicant for a license or by a licensee or information required by statute or by the Commission's regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects.

Contrary to the above, on January 6, 1997, and on May 5, 2004, TVA provided information to the Commission that was not complete and accurate in all material respects, related to NRC Generic Letter 89-10, "Safety-Related Motor-Operated Valve Testing and Surveillance" testing program. Specifically, in a letter dated January 6, 1997, TVA responded to a prior NRC question and stated that "Closure of valves FCV-74-52 and FCV-74-66 is not required by plant procedures to operate the RHR system in the suppression pool cooling mode. Therefore, these valves have no

'redundant' safety function and will not be included in the GL-89-10 program." This information was inaccurate because the FCV-74-52 and FCV-74-66 valves do have a safety function to shut to operate the RHR system in the suppression pool cooling mode as described in EOI Appendix-17A, "RHR System Operation Suppression Pool Cooling," and should therefore have been included in Browns Ferry's GL 89-10 MOV monitoring program.

Additionally, TVA also provided incomplete and inaccurate information in a letter to NRC dated May 5, 2004. This letter referenced 18 valves, including FCV-74-52 and FCV-74-66, "that are not in the GL 89-10 program since the valves are normally in their safety position." This letter stated that "TVA's review and documentation of the design basis for the operation of each Unit 1 MOV within the scope of the GL 89-10 program, the methods for determining and adjusting its switch settings, testing, surveillance and maintenance are the same as with the Units 2 and 3 program."

This information was material to the NRC because it was used, in part, as the basis for determining that valves FCV-74-52 and FCV-74-66 did not meet the conditions necessary that would require them to be in Browns Ferry's GL 89-10 MOV monitoring program.

Background

Tennessee Valley Authority (TVA) incorrectly determined that flow control valves FCV-74-52 and FCV-74-66 were "passive" based on operating in their safety position during normal alignment. Additionally, TVA failed to identify that FCV-74-52 and FCV-74-66 are required to be closed to enable Residual Heat Removal (RHR) to operate to the suppression pool cooling mode, per Emergency Operating Instruction (EOI) Appendix-17A.

By letter dated January 6, 1997, TVA responded to NRC inspector follow-up item 50-260, 296/95-19-01 regarding the reduced scope of motor-operated valves (MOVs) in the NRC Generic Letter (GL) 89-10, "Safety-Related Motor-Operated Valve Testing and Surveillance," program for Browns Ferry Nuclear Plant (BFN) Units 2 and 3. This letter stated in part that "Closure of valves FCV-74-52 and FCV-74-66 is not required by plant procedures to operate the RHR system in the suppression pool cooling mode. . ." As a result, FCV-74-52 and E-1 of 4

Reply to Notice of Violation; EA-11-252 FCV-74-66 were removed from the GL 89-10 program in 1997, in accordance with Supplement 1 to GL 89-10.

As identified during the root cause analysis conducted to address the issues associated with the failure of FCV-74-66 in BFN Unit 1, TVA discovered that the statement "Closure of valves FCV-74-52 and FCV-74-66 is not required by plant procedures to operate the RHR system in the suppression pool cooling mode. . ." was inaccurate. Specifically, the revision of the EOI, Appendix 17A, that was in place in January 1997 included a step to verify that the FCV-74-52 or FCV-74-66 valve was closed as part of performing the steps to place the RHR system in the suppression pool cooling mode. As required by 10 CFR 50.9(b), TVA provided written notification to the NRC by letter dated October 20, 2011, acknowledging the inaccuracy of its January 6, 1997 letter. Additionally, TVA provided written notification to the NRC by letter dated December 19, 2011, acknowledging the inaccuracy of its May 5, 2004, letter.

With respect to FCV-74-52 and FCV-74-66 and the GL 89-10 program, TVA will implement the following actions.

" Add 1, 2, 3 - FCV-74-52 and 1, 2, 3 - FCV-74-66 to the GL 89-10 program.

  • Develop or revise an existing procedure to specifically provide the criteria for determining GL 89-10 program scope, including active/passive classification.

Reason for the Violation The reasons for this violation of 10 CFR 50.9, "Completeness and accuracy of information," are as follows.

FVA failed to apply adequate technical rigor to the review process for regulatory submittals. The responsible licensing engineer was requested by a reviewer of the January 1997 submittal to verify the statement regarding closure of valves FCV-74-52 and FCV-74-66. Verification was done through verbal confirmation from Engineering without documentation supporting the conclusion.

"I VA procedures did not contain sufficient details governing the verification process for regulatory submittals. WVA procedures in place at the time of the 1997 letter only provided guidance on acceptable methods of verification. In addition, the procedure stated that method of verification remained at the discretion of the technical lead; not the responsible licensing engineer.

STVA personnel assigned to the BFN Unit 1 restart licensing failed to follow procedures governing the verification process for regulatory submittals. The information provided in the May 5, 2004, letter related to BFN Unit 1 was verified to the extent required to ensure the BFN Unit 1 valves were described in a manner equivalent to the BFN Units 2 and 3 valves. As stated in the 2004 letter, the basis for excluding the BFN Unit 1 valves from the GL 89-10 program was the same as the BFN Units 2 and 3 valves.

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Reply to Notice of Violation; EA-11-252 Corrective Steps That Have Been Taken and Results Achieved As stated above, TVA provided written notification to the NRC by letter dated October 20, 2011, acknowledging the inaccuracy of its January 6, 1997, letter, in accordance with 10 CFR 50.9(b).

Additionally, TVA provided written notification to the NRC by letter dated December 19, 2011, acknowledging the inaccuracy of its May 5, 2004, letter.

Procedural requirements in TVA procedure BP-213, "Managing TVA's Interface with NRC,"

governing the verification of information contained in NRC submittals were enhanced in 2002.

These enhancements, which included the following, are contained in the current revision of BP-213:

  • Designating oversight responsibility for the submittal verification process to Licensing.
  • Specifying which NRC submittals require verification.

" Describing which types of statements in NRC submittals require verification.

" Providing detailed requirements for verification packages.

With respect to the failure of BFN Unit 1 restart licensing personnel to follow the procedure governing the verification process for regulatory submittals (i.e. BP-213), procedure use and adherence has since been reinforced as one of TVA's fundamental human performance tools.

Management expectations regarding procedure use and adherence are communicated regularly through TVA Nuclear corporate and site communications and are further reinforced through TVA's Nuclear Fleet Focus Handbook.

Extent of Condition Misapplication of the criteria for determination of active/passive function of 1-FCV-74-66 resulted in inappropriate classification and removal from the GL 89-10 program. This contributed to the untimely identification of the valve failure. This misapplication of the criteria also resulted in providing the NRC inaccurate information in associated correspondence and submittals used by the NRC in making the decision to approve the exclusion of the FCV-74-52 and FCV-74-66 valves from the BFN GL 89-10 program. As a result, the extent of condition is considered to include submittals to NRC that included information describing the results of TVA application of criteria for defining the scope of regulatory programs.

To address this extent of condition, focused self-assessments in accordance with procedure NPG-SPP-03.1.11, "NPG Self Assessment Program," will be performed for the following BFN Units 1, 2, and 3, regulatory programs to verify that applicable scoping criteria have been correctly applied to establish program scope, (Problem Evaluation Report number 369800).

The scoping criteria and the basis for inclusion/exclusion in scope will be documented in an NPG-SPP level technical basis document (to be developed as part of this action if it does not currently exist for the program).

  • Air Operated Valve Program

" Breaker Testing and Maintenance Program E-3 of 4

Reply to Notice of Violation; EA-11-252

  • Buried Cabling Program
  • Buried Piping Program/Groundwater Protection Program
  • Equipment Qualification Program
  • Inservice Inspection Program
  • Inservice Testing Program
  • Instrument Setpoint Program
  • Motor Operated Valve Program
  • Seismic Monitoring Instrumentation Program
  • Seismic Qualification Program
  • Pumps
  • Motors

" Heat Exchangers

  • Chillers
  • Appendix R/NFPA-805
  • Reactor Vessel Internals As required by the TVA Corrective Action Program (CAP) and NPG-SPP-03.1.11, any deficiencies in the application of scoping criteria for these regulatory programs, which are identified during the focused self-assessments, will be documented in the TVA CAP.

In accordance with procedure NPG-SPP-03.5, "Regulatory Reporting Requirements," TVA Licensing will review and evaluate each of these deficiencies entered in CAP to determine ifthe deficiency is reportable in accordance with 10 CFR 50.9. In determining reportability of identified deficiency in accordance with 10 CFR 50.9, TVA will review applicable information submitted to NRC in other BFN GL 89-10 submittals, other BFN Unit 1 restart submittals, and other BFN Units 2 and 3 submittals related to these regulatory programs starting from time of program development.

TVA will notify the NRC in accordance with 10 CFR 50.9(b) for identified deficiencies that meet the reporting requirements delineated in 10 CFR 50.9.

Corrective Steps That Will Be Taken All identified corrective actions to avoid future violations have been implemented.

The results of the extent of condition reviews and any required NRC notifications are expected to be completed by September 28, 2012.

Date When Full Compliance Will Be Achieved For the 10 CFR 50.9 violation described in EA-1 1-252, TVA achieved full compliance with the October 20, 2011, and December 19, 2011, NRC notification letters.

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