ML18033A986
| ML18033A986 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/13/1989 |
| From: | Michael Ray TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8910190068 | |
| Download: ML18033A986 (8) | |
Text
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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ESSION NBR:8910190068 DOC.DATE: 89/10/13 NOTARIZED: NO FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 50-260 Browns Ferry Nuclear Power Station, Unit 2,.Tennessee 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee AUTH.NAME AUTHOR AFFILIATION RAY,M.J.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document, Control Branch (Document Control Desk)
SUBJECT:
Requests that date for response to NRC 890911 ltr re response to violation 89-17 be extended to 891027.
DISTRIBUTION 'CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation R sponse NOTES:1 Copy each to: B.Wilson,D.M.Crutchfield,B.D.Liaw,S.Black R.Pierson, 1 Copy each to: S.Black,D.M.Crutchfield,B.D.Liaw, R.'Pierson,B.Wilson 1 Copy each to:
S. Black,D.M.Crutchfield,B.D.Liaw, R.Pierson,B.Wilson DOCKET 05000259 05000260 05000296 05000259 05000260 05000296 RECIPIENT ID CODE/NAME PD ERNAL: ACRS AEOD/DEIIB DEDRO NRR/DEST DIR NRR/DOEA DIR 11 NRR/DREP/RPB 10 NUDOCS-ABSTRACT OGC/HDS2 RES MORISSEAU,D EXTERNAL: LPDR NSIC NOTES'OPIES LTTR ENCL 1
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RECIPIENT'D CODE/NAME
,GEARS,G AEOD AEOD/TPAD NRR SHANKMAN,S NRR/DLPQ/PEB NRR/DREP/EPB 10 NRR/PMAS/ILRB12
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1 NOIE 'IO ALL t'RIDSit RECIPIENIS PIZASE HELP US IO itEDOCE HASTE!
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LTTR 30 ENCL 30
TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 5H 157B Lookout. Place U.S. Nuclear Regulatory Commission ATTN:
Document. Contr:ol Desk washington, D.C.
20555 Gentlemen:
In the Matter of Tennessee Valley Authority Docket Hos. 50-259 50-260 50-296 BROl<NS FFRRY NUCLFAR PLANT (BFN) RESPONSE TO VIOLATION 89 COMM1TMENT SCHEDULE CHANGE
Reference:
TVA letter to HRC dated September ll, 1989, "Browns Ferry Huclear Plant.
(BFH) - Units 1, 2, and 3
NRC Inspection Report Hos 50-259/89-17, 50-260/89-17, and 50-296/89-17
Response
to Violation-"
In our response to Hot.ice of Violation 89-17 (reference)'VA committed to completing the safet.y evaluations (SE) for design change notices (DCN) H3858A and H0166A by.October 13, 1989.
The SE for DCN H0166A has been complet.ed and concluded that. no unreviewed safety question exists for this modification.
During performance of the safet.y evaluat.ion for DCN H3858A, it was identified that a copy of confirmatory, vendor 'information was required t.o properly document. the evaluation.
Due to the additional time required to obtain this infoxv1ation, TVA i" requesting that the date for this commitment be ext.ended to October 27, 1989.
The applicable sections of our referenced response ar.e tanclosed with the revised commitment date identified.
Please refer any questions concerning this submittal to Patrie'k P. Carier, BFN, Sit.e Licensing, (205) 729-3570.
Very truly yours, TENNESSEE VALLEY AUTHORITY Manager,s Nuclear Lac nsing and Regulatory Affairs 0
Enclosure cc:
See page 2
Ot.i(J<)OZi
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An Equal Opportunity Employer
0'
U.S. Huclear Regulatory Commission OGT 1! 18i":
cc. (Fnclosure):
Hs.
S.
C. Black, Assistant Director for Projects.
TVA Projects Division U.S. Huclear Regulatory Commission One White Flint, Hortb
'1555 Rockville Pike Roc'kville, Haryland 20852 Hr. B. A. wilson, Assistant Director for Inspection Programs TVA Proje cts Division U.S. Huclear Repulatory Commission Region II 101 Hariet.ta Street, tM, Suite 2900 Atlanta, Georgia 30323 HRC Resident Inspector Brogans Ferry Huclear Plant Route 12, Box 637
- Athens, Alabama 35609-2000
ENCLOSURE TVA letter to HRC dated September 11, 1989 "Bromis Ferry Nuclear Plant (BFN) Units 1, 2, and 3
HRC 1nspection'Report Nos 50-259/89-17, 50-260/89-17, and 50-296/89-17
Response
to Violations"
Enclosure 1
Page 2 of 5 The training program for qualifying preparers has been expanded to
'nclude more time for discussion of evaluation examples and a more detailed SE writing workshop with a greater emphasis on technical content.
ALso, the requirements for successfully completing this training have been made more stringent.
The procedures and training continue to emphasize the importance of obtaining technical assistance, as required, during the review process.
The SEs for ECN P7113 and DCN H0166A have been completed and concluded that no unreviewed safety questions exists for these modifications.
The corporate procedure for evaluating change-as required by 10 CFR 50.59 has recently been revised to incorporate indu..try guidance from Nuclear Safety Analysis Center (HSAC) 125, Guidelines for 10 CFR 50.59
- SEs, and to include additional levels of revi.ew and quality assurance monitoring of the process.
4.
Corrective Ste is Mhich Mill be Taken to Avoid Further Violations TVA plans to review previously closed change packages to, ensure that changes to the facility as described in the SAR are properly documented.
The review will be part of tho UFSAR verification program and will involve reviewing those change notices closed, after the January 1988 cut-off date for inclusion in the last BFN FSAR update and before April 1989.
This effort will be completed in support of the next UFSAR annual update (Amendment 7).
The SE for DCN H3858A will be performed to properly document that no unreviewed safety question exists for this modification.
5.,
Date'hen Full Comiliance Mill be Achieved The review of change packages closed between January 1988 and April 1989 will be completed in support of the next UFSAR annual update (Amendment 7).
The. SE for DCH H3858A will be completed by October 27, 1989.
Violation 2 Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained for activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Contrary to the above, four examples of a failure to properly implement written procedures are identified below:
a
~
ECH E-2-P7010 was invalidated by the issuance of DCN H1239 Revision A, which is contrary to procedure PI 86-03, which did not permit use of a DCH to correct an ECH for which a 10 CFR 50.59 review is not valid.
b.
intent change-to workplans (MPs) including change number two to Mp 2317-88 and multiple changes to MP 2069-88, were incorrectly classified as non-intent change.,
and were not processed in, accordance with the requirements of Site Director Standard Practice (SDSP), 8.2.
Enclosure 2
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~
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1.
The review of change will be completed in Report annual update Sundry List of Commitments package".closed between January 1988 and April 1989 support of the next Updated Final Safety Analysis (Amendment 7).
2.
The safety evaluation for Design Change Notice (DCN) H3858A.will'be completed by October 27, 1989.
3.
The changes to procedure Site Director Standard Practice (SDSP) 17.2 and SDSP-8.4 will be'ompleted by October 2, 1989.