ML18038B738

Valley Authority

ATTN:. Mr. Oliver D. Kingsley. Jr.

President,

TVA Nuclear and

Chief .Nuclear Officer

6A Lookout Place

1101 Market Street

Chattanooga,

TN

37402-2801

SUBJECT.:

NOTICE OF VIOLATION

(NRC Inspection Report Nos. 50-259,

50-260.

and 50-296/96-05)

Dear

Mr . Kingsley:

This refers to the. inspection

conducted

on Apri.l 28 through June 8, -1996. at

your Browns,Ferry. facility.

The inspection included

a review of the

circumstances

surrounding the response of the Unit 2 Reactor

Core Isolation

Cooling (RCIC) System following a reactor scram on May 10.

1996.

The results

of our inspection were sent to you by letter dated June

19,

1996.

A closed,

predecisional

enforcement

conference

was conducted in the Region II office on

July 11.

1996, with members of your staff to discuss the apparent violations,

the root causes,

and your corrective actions to preclude recurrence.

A list

of conference

attendees.

NRC slides.

and a copy of your presentation

materials

are enclosed.

Prior to the conference,

you provided in a letter dated July 8..

1996, your views on the application of the Enforcement Policy .in this case.

Based

on the information developed

during the inspection

and the information

that you provided during the conference,

the

NRC has determined that

violations of NRC requi rements

occurred.

The. violations are cited in the

enclosed

Notice of Violation (Notice) and the circumstances

surrounding

them

~ .are described in detail in the subject. inspection report.

Violation A

involved'the inoperability of'he Unit 2 RCIC for a period greater than that

.

allowed by Technical Specifications

(TSs)..

.Specifically,

on May 10,

1996, in

'esponse

to. a feedwater transient

and subsequent

reactor

scram,

RCIC briefly

initiated and then tripped on high turbine exhaust

pressure

which rendered the

system inoperable.

The root causes of the

RCIC inoperability'ere determined

to be inadequate

design review and post-modification testing for the

replacement of the turbine exhaust

check valve during the 1996 refueling

outage.

Specifically. the engineering evaluation associated

with the check

valve replacement

used

improper

steam flow inputs

and failed to consider

RCIC.

system startup transient behavior.

Further.

engineering failed to recognize

and requi re the, performance of an adequate

post modification test to assure

the equipment

change did not affect full RCIC system. performance.

As a result

of these deficiencies,

the RCIC turbine exhaust

peak pressure

exceeded

the

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turbine trip setpoint causing'the

system to fail when called upon to operate

on May 10,

1996.

Although the inoperability of RCIC did not have

a significant consequence

to

safety because

RCIC was not needed to mitigate the May 10.

1996 transient.

the

violation is nonetheless

of significant regulatory concern

because

multiple

fai lures occurred in your engineering

design,

review.

and testing programs

.

which permitted. the plant to operate

under conditions in which RCIC could not

~

perform its intended function in the automatic

mode of.operation'.

Although

NRC recognizes that

RCIC is not

a 10 CFR Part 50. Appendix

B safety system, it

is important to safety.

and your failure to ensure

adequate

design controls

and conduct testing to verify the system

was fully functional following system

alterations

resulted in a significant tailure to comply with TS.

Therefore.

Violation A is classified in accordance with the "General

Statement ot Policy

and Procedures

for NRC Enforcement Actions" (Entorcement Policy),

NUREG-1600,

as

a Severity

Leve1 III violation.

In,accordance

with the Enforcement Policy;

a base civil penalty in the amount

of $50,000 is considered for a Severity Level III violation.

Because

your

facility has

been the subject of escalated

enforcement'actions

within the last

2 years,

the

NRC considered

whether credit was warranted for Identic'ication

and Corrective Action in accordance with the civil penalty assessment

process

described in Section VI.B.2 of the Enforcement Policy.

In this case,

the

NRC

.concluded that it is not appropriate to give credit for Identification because

the violation was discovered

as

a result of.the Hay 10.

1996 event.

and prior

opportunities existed for you to identify the problem earlier.

These

opportunities

included your initial engineering calculation

and modification

review processes;

your designer/checker

independent verification process;

review of a previously issued

General Electric Service Information Letter,

that provided you information relative to a more appropriate setting for the

RCIC turbine exhaust

pressure trip setpoint;

and conduct of testing following

implementation of the check valve modification.

With regard to consideration

for Corrective Action, at the conference

you stated that your actions

i'ncluded:

(1) performance of a detailed root cause analysis;

(2)

implementation of higher turbine exhaust 'trip setpoints;

(3) performance of an

extent of condition review on previously issued .and implemented design

change

notices;

(4) counseling of involved employees

and reinforcement of

expectations

and lessons

learned for other engineering

personnel;

(5)

establishment

of an Engineering

Review Board to independently

review design

changes

and non-conformances;

and (6) procedural

revisions to effect

improvements in design reviews, coordination

between design'and

system

engineering,

the independent verification process,

and designer testing

A Severity Level II violation and proposed civil penalty of $80.000 were issued

on

February

14.

1996

(EA 95-220) related to employee discrimination in Oepartment of Labor Case

No.

93-ERA-044.

0

'program responsibilities.

Based

on the above.

the

NRC determined that your

corrective actions

were comprehensive,

and credit was warranted for this

factor.

In the application of the Enforcement Policy as described

above.

NRC considers

previous escalated

enforcement. actions.

and in. this case,

would normally

. result. in a base civil penalty for this action..

However', the purpose. of this:

portion 'of the. Policy is to reflect past licensee

performance,

including

consideration of whether the current violation at issue is

a relatively

isolated Severity Level III violation.

In this case,

there

has

been

a

previous escalated

enforcement action, which. although issued in 1996.

occurred in 1993,

and is greater than two years prior to the occurrence of

th';s violation.

This fact, in conjunction with the recent overall

good

performance at Browns Ferry warrants the exercise of discretion in accordance

with Section VII.B.6 of the Enforcement Policy.

Therefore, after consultation

with the Director, Office of Enforcement,

and the Deputy, Executive Director

for Nuclear Reactor Regulation,

Regional Operations

and Research.

no civil

penalty is being proposed in this case.

However. significant violations in

the future could'esult in a civil penalty.

Violation B has

been categorized

at Severity Level IV and is also described in

the enclosed

Notice.

It involved the failure to ensure that the post-

modification testing required by your In-Service Testing Procedures

were

performed following the aforementioned

RCIC turbine exhaust

check valve

replacement

and the High Pressure

Coolant Injection turbine exhaust

valve

replacement

conducted during the 1996 refueling outage.

Although conduct of

such testing

may not have prevented Violation A. Violation B is of concern

because it was identified by the

NRC, it revealed

weaknesses

in personnel

knowledge

and coordination of American Society of Mechanical

Engineers

Section

XI testing requirements,

and had the potential for impacting

a safety

system required for accident mitigation.

You are required to respond to this letter and should follow the. instructions

specified in the inclosed. Notice w'hen preparing your response.

In

your'esponse,

you should document the specific actions taken

and any additi.onal

actions .you plan to prevent recurrence..

After reviewing your response to this

Notice, including your proposed corrective actions

and the results of future

inspections.

the

NRC will determine whether further

NRC enforcement

action is

necessary

to ensure

compliance with NRC regulatory requi rements.

In accordance

with 10 CFR 2.790 of the NRC's "Rules of Practice,"

a copy of

this letter, its enclosure.

and your response will be placed in the

NRC Public

Document

Room (PDR).

To the extent possible,

your response

should not include

Cl

any personal

privacy. proprietary..

or safeguards

information so that it can be

placed in the

PDR without redaction.

Sincerely,

Original signed

by L. A. Reyes

Stewart

D: Ebneter.

Regional Administrator

Docket No. 50-260

License

No.

DPR-52

Enclosures:

1.

Notice of Violation

2.

List of, Conference

Attendees

3.

NRC Slides

4.

Licensee Presentation

Material

cc w/encls:

0.

J'. 2eringue.

Senior Vice President

'uclear Operations

Valley Authority

.6A Lookout Place

1101 Market,Street

.

Chattanooga.

TN

37402-2801

Dr. Mark 0. Medford, Vice President

Technical

Services

Valley Authority

6A'ookout

Place'101

Market Street

Chattanooga.

TN

37402-2801

\\

R.

D:. Machon.

~Site Vice President

Browns Ferry Nuclear Plant

Valley Authority

P. 0.

Box 2000

Decatur,

35602

Raul

R. Baron, General

Manager

Nuclear Licensing

Valley Authority

4G Blue Ridge

1101 Market Street

Chattanooga,

TN 37402-2801

cc w/encls:

(Cont'd on Page 5)

.

Cl

cc w/encls (Cont'd)

Pedro Salas

~ Site Licensing Manager

Browns Ferry Nuclear Plant

Valley Authority,

,P. 0.

Box 2000

Decatur,

Al

35602

TVA Representative

Valley Authority

One Massachusetts

Avenue. Suite

300-

Washington,

DC

20001

General

Counsel

Valley Authority

ET 10H

400 West Summit Hill Drive

Knoxville. TN

37902

Chairman

Limestone County Commission

310 West Washington Street

Athens.

35611

State Health Officer

Alabama Department of .Public Health

434 Monroe Street

Montgomery.

36130-1701

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