ML14153A665
| ML14153A665 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  (DPR-033, DPR-052, DPR-068) |
| Issue date: | 05/30/2014 |
| From: | James Shea Tennessee Valley Authority |
| To: | Document Control Desk, NRC/RGN-II |
| References | |
| EA-14-005, IR-13-005 | |
| Download: ML14153A665 (7) | |
Text
Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 May 30,2014 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission 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-14-005 10 CFR 2.201
References:
- 1. Letter from TVA to NRC, "Response to Apparent Violation in NRC Integrated Inspection Report 05000259/2013005, 05000260/2013005, and 05000296/2013005; EA-14-005," dated March 17, 2014
[ML14077A581]
- 2. Letter from NRC to TVA, "Browns Ferry Nuclear Plant-NRC Integrated Inspection Report, Final Significance Determination of White Finding and Notice of Violation, 05000259/2014002, 05000260/2014002, and 05000296/2014002," dated April 30, 2014 [ML14120A374]
In accordance with Reference 2, the Tennessee Valley Authority (TVA) is responding to Notice of Violation EA-14-005 within 30 days of the date of the letter (i.e., May 30, 2014).
As required by Title 10 of the Code of Federal Regulations (10 CFR) 2.201, the TVA response to this notice of violation includes: 1) the reason for the violation, 2) the corrective steps that have been taken and the results achieved; 3) the corrective steps that will be taken; and 4) the date when full compliance will be achieved. These responses are provided in the Enclosure to this letter.
As stated in Reference 1, TV A does not contest this violation or the staffs determination of the significance for the identified White finding.
Printed on recycled paper L44 140530 001
U.S. Nuclear Regulatory Commission Page 2 May 30, 2014 There are no new regulatory commitments contained in this response. Should you have any questionsconcerning this submittal, please contact J. L. Paul, Nuclear Site Licensing Manager, at (256) 729-2636.
Respectfully, rW/TShea fice/President, Nuclear Licensing
Enclosure:
Reply to Notice of Violation; EA-14-005 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-14-005
Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Reply to Notice of Violation; EA-14-005 Restatement of Violation Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q) requires, in part, that a holder of a license under Part 50 shall follow and maintain the effectiveness of the emergency plan that meets the planning standards of 10 CFR 50.47.
10 CFR 50.47(b)(2) states, in part, that adequate staffing to provide initial facility accident response in key functional areas is maintained at alltimes. Tennessee Valley Authority (TVA) Nuclear Power Radiological Emergency Plan (NP-REP), AppendixA, Figure A-1, Site Emergency Organization, Browns Ferry Nuclear Plant, defined the emergency plan staffing requirements for keyfunctional areas including the staffing of a Shift Technical Advisor (STA) and Incident Commander (IC).
Contrary to the above, from May 21, 2007, through October 30, 2013, the TVA failed to follow and maintain the effectiveness of an emergency plan that met the planning standards of 10 CFR 50.47 when the TVA did not ensure adequate staffing to provide initial facility accident response in key functional areas was maintained at all times.
Specifically, TVA's process for maintaining minimum emergency response shift staffing failed to ensure continuous staffing of emergency response roles as defined in NP-REP, Tennessee Valley Authority Nuclear Power Radiological Emergency Plan as evidenced by the following examples:
1.
Failure to continuously staff the STA position beginning May 21, 2007 2.
Failure to continuously staff the IC position beginning December 21, 2012
Background
As described in the Nuclear Regulatory Commission's (NRC's) Integrated Inspection Report for Browns Ferry Nuclear Plant, 05000259/2013005, 05000260/2013005, and 05000296/2013005, Preliminary White Finding and Apparent Violations1, the NRC identified an apparent violation of 10 CFR 50.54(q), Emergency Plans, for TVA's failure to maintain plant staffing levels in accordance with NPREP. The NRC stated that TVA's process for maintaining minimum emergency response shift staffing failed to adequately maintain staffing of the STA and IC to ensure initial accident response in all key functional areas.
On April 25, 2007, NRC Safety Evaluation (SE) associated with License Amendment Request (LAR) Technical Specification (TS) No. 459was issued2. Asdocumented in the SE, the minimum control room staffing specified in the LARwas used, in part, as the basis for the license amendment approval. The NRC SE reflects that TVAstated that a total staffing level of one Shift Manager (SM), four Unit Supervisors (USs), six Reactor Operators (ROs), eight Auxiliary Unit Operators (AUOs), and one STA were needed. These staffing levels also met the minimum on-shift facility staffing requirements defined in Figure A-1, Site Emergency Organization, of Appendix A, Browns Ferry Nuclear Plant, contained in revision 84 of NP-REP.
This SE is referenced in the Fire Protection License Condition issued for each of the three BFN units. However, before receiving NRC approval for TS-459, Operations Department Procedure (OPDP)-1, "Conduct of Operations," was changed to specify that only three USs were required.
1 ADAMS Accession No. ML14045A320 2 ADAMS Accession No. ML071160431 E1
Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Reply to Notice ofViolation; EA-14-005 On February 17, 2010, as part ofthecauseanalysis of the NRC Appendix Rinspection findings itwas identified that the "shift manning defined in TVA ProcedureOPDP-1, was inconsistent with NRC-Approved SE dated April 25, 2007," (TS-459). Subsequently, TVA completed a staffing evaluation tovalidate Safe Shutdown Instruction (SSI) required staffing and incorrectly concluded that the STA was not required forSSIs. A Licensing Commitment Evaluation was completed to changethe minimum control room staffing discussedin TS-459. It was not recognized thatthe change to OPDP-1 also needed tobe reviewed for impact tothe Fire Protection Licensing Condition and the Radiological Emergency Plan. The Licensing CommitmentEvaluation used the staffing evaluationas the basis for the commitment change.
On June 17, 2013, itwas identified that the STAstaffing specified inTVA Procedure OPDP-1 was in conflict with the staffing specified in the Radiological Emergency Plan. Infollow up, another assessment of operation's staffing was completed and on October 3, 2013, an 8-hour 10 CFR 50.72 notification was made to the NRC (reference Event Notification 49406).
On February 14, 2014, in Integrated Inspection Report 05000259/2013005, 05000260/2013005, and 05000296/2013005, "Preliminary White Finding and ApparentViolations," the NRC identified an apparent violation (EA-14-005) of10 CFR50.54(q), Emergency Plans, forTVA's failure to maintain plant staffing levels in accordance with NP-REP3. Specifically, TVA's process for maintaining minimum emergency response shift staffing failed to adequately maintain staffing ofthe STAand IC to ensure initial accident response in all keyfunctional areas.
Reason for the Violation The reasons for this violation of 10 CFR 50.54(q), "Emergency Plans," are as follows.
TVA failed to conduct an adequate licensing and regulatory review of staffing requirements related to a procedure change to OPDP-1 in2007 that did not identify the change should have been processed inaccordance with 10 CFR 50.54(q).
Revisions of procedure SPP 2.1, "Administration of Standard Programs and Processes(SPPs); and Standard Department Procedures (SDPs)," diluted and then removed a review requirement to perform a 10 CFR 50.59 applicability review that resulted in changes to procedures that contained 10 CFR 50.54(q) information that were not properly evaluated.
The Independent Quality Review (IQR) specified in SPP 2.1 relied onlyon a single barrier (IQR checklist)to review a change forgeneral licensingand other applicable requirements resulting inchanges to proceduresthat did not address all regulatory requirements.
3 ADAMS Accession No. ML14045A320 E2
Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Reply to Notice of Violation; EA-14-005 Corrective Steps That Have Been Taken and Results Achieved On November 1, 2013, BFN Operations Department issued a Standing Order to verify that shift staffing includes four Unit Supervisors and an additional person as STA.
On December 31, 2013, NPG Standard Department Procedure OPDP-1, Conduct of Operations, was revised to ensure the appropriate Operations minimum shift staffing levels.
These levels are one Shift Manager, four USs, six ROs, eight AUOs, and one Shift Technical Advisor, ensuring the minimum control room on-shift staffing required by NP-REP is met.
Additional guidance has been provided in the following areas:
All commitment changes will receive a documented peer review by a second site licensing engineer. The focus of the documented peer review shall be to ensure the correct regulatory change processes have been used to make the change.
An Interim Licensing Compliance Review Checklist is developed, for use by the procedure writing organizations and document reviewers, to provide them with a tool to ensure the correct licensing basis documents are referenced when revising procedures.
Training Needs Analyses have been performed for Operations, Engineering, and Licensing to address the knowledge deficiency related to the hierarchies of documents and their associated regulatory required change processes that comprises the licensing basis of the facility.
Corrective Steps That Will Be Taken The following TVA Root Cause Analysis (RCA) corrective actions will be taken:
A procedure will be developed and issued to establish a Licensing Compliance Review process addressing administrative and technical procedures not covered under the 10 CFR 50.59 review process. (RCA Action 838977-009)
Procedure OPDP-1 "Conduct of Operations" will be revised to accurately reflect the Source Documents and Notes represented in the procedure. (RCA Action 838977-008)
Revise a Standard Programs and Processes procedure to include a step to invoke the application of the Licensing Compliance Review procedure during the procedure revision process and incorporate a step into the IQR Checklist for the IQR to validate that the Licensing Compliance Review was completed. (RCA Action 838977-010)
Implement the results of the training needs analyses performed to address the knowledge deficiency related to the hierarchy of documents (and their associated regulatory required change processes) that comprise the licensing basis of the facility.
(RCA Actions 838977-017, -018, -021)
TVA has hired and is directing an external contractor with the expertise and formal process to perform an evaluation of operations minimum shift staffing. The evaluation should include a task analysis for three-unit operation and consider all required licensing basis functions. (RCA Action 790109-019)
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Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Reply to Notice of Violation; EA-14-005 Date When Full Compliance Will Be Achieved Full compliance was achieved on December 31, 2013 when NPG Standard Department Procedure OPDP-1, Conduct of Operations, was revised.
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