ML18038B956

Forwards Response to NRC Re Violations Noted in Insp Rept 50-260/97-08.Corrective Actions:Se Performed for Dcn S39677A to Address New Sys Alignment

ML18038B956
Person / Time
Site:	Browns Ferry
Issue date:	09/26/1997
From:	Crane C TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-260-97-08, 50-260-97-8, NUDOCS 9710070071
Download: ML18038B956 (16)

Text

CATEGORY j.

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9710070071 DOC.DATE: 97/09/26 NOTARIZED: NO DOCKET FACIL:50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 UTH.NAM'UTHORAFFILIATION NE,C.M.

Tennessee Valley Authority ECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)'UBJECT:

Forwards response to NRC 970829 ltr re violations noted in insp rept 50-260/97-08 on 970622-0802.Corrective actions:SE has been performed for DCN S39677A to address new sys alignment.

DISTRIBUTION CODE:

IE01D COPIES RECEIVED:LTR ENCL SIZE:'ITLE:

General (50 Dkt)-Insp Rept/Notice of.Violation Response NOTES:

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NOTE TO ALL "RIDS" RECIPZENTS:

t PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTZON LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)

ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED:

LTTR 20 ENCL 20

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Tennessee Valley Authority, Post Offce Box 2000, Decatur, Alabama 35609-2000 Christopher M. (Chris) Crane Vice President, Browns Ferry Nuclear Plant September 26, 1997 U.

S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.

20555 10 CFR 2.201 Gentleman:

In the Matter of Tennessee Valley Authority Docket No. 50-260 BROWNS FERRY NUCLEAR PLANT (BFN)

NRC INTEGRATED INSPECTION

REPORT, 50-260/97-08 REPLY TO NOTICE OF VIOLATION (NOV)

This letter provides TVA's reply to the subject NOV transmitted by letter from M.. S. Lesser, NRC, to 0.

D.

Kingsley Jr.,

TVA, dated August 29, 1997.

In the letter, a

violation of NRC requirements was identified.

The violation involved the failure to perform a written safety evaluation as required by 10 CFR 50.59 to support a, change to the facility as described in TVA's Updated Final Safety Analysis Report.

TVA admits this violation.

Enclosure 1 contains the reply to the NOV.

Enclosure 2

contains the commitment made in this -letter. If you have any questions, please contact me at (205) 729-3675.'incerely, C.

M.

rane r

)

~4 Enclosures cc:

See page 2

llllllllllllllllllllllllllllllllllllllll 9'7i007007i 970'tf26 PDR ADOCK 05000260 8

PDR

U.S. Nuclear Regulatory Commission Page 2

September 26, 1997 Enclosures cc (Enclosures):

Regional Administrator U.S. Nuclear Regulatory Commission Region II 61 Forsyth Street S.W.

Suite 23T85

Atlanta, Georgia 30303 Mr. Mark S. Lesser, Branch Chief U.S. Nuclear Regulatory Commission Region II 61 Forsyth Street S.W.

Suite 23T85

Atlanta, Georgia 30303 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road

Athens, Alabama 35611 Mr. J.

F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852

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ENCLOSURE 1

TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNIT 2 INSPECTION REPORT NUMBER, 50-260/97-08 REPLY TO NOTICE OF VIOLATION (NOV)

RESTATEMENT OF THE VIOLATION "During an NRC inspection conducted on June 22 August 2,

1997, a violation of NRC requirements was identified.

In accordance with the General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

10 CFR 50.59, "Change, Tests and Experiments," provides, in part, that the licensee may make changes in the facility or procedures as described in the safety analysis report (SAR) without prior Commission approval, unless the proposed change involves an unreviewed safety question.

The licensee shall maintain records of the changes to the extent that the changes constitute a change as described in the SAR.

These records must include a written safety evaluation which provides the basis for the determination that the change does not involve an unreviewed safety question.

Contrary to the above, on May 20,

1996, a written safety evaluation was not prepared for plant modification DCN No.

S39677A which revised load limitation notes on drawings 0-45E732-1 and 0-45E732-3 (FSAR Figures 8.5-12A and 8.5.13A respectively).

This change to the FSAR permitted a new system alignment which permitted parallel operation of transformers TS1E and TDE with a load limit of 500 KVA when energized from the 4160 V Shutdown Board l(Btl This is a Severity Level IV Violation (Supplement I)."

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'ZVA's REPLY TO THE VIOLATION 1.

Reason For The Violation The root cause of this violation was an inadequate procedure in that the procedure could be misinterpreted by the user.

Site Standard Practice (SSP) 12.13, Revision 5, effective January 14,

1993, which was utilized to perform the safety assessment (SA) for DCN S39677A, did not contain adequate guidance for the identification of non-significant SAR changes by the Safety Assessment/Safety Evaluation (SA/SE) preparer.

In particular, SSP 12.13, Revision 5, allowed a safety system alignment change (safety system functional change),

which resulted in an operator action being reflected on a

FSAR drawing, without a SE.

The definition of non-significant FSAR changes contained in SSP 12.13, Revision 5, stated in part, "A change to a drawing which is in the FSAR, is not necessarily a change to the facility as described in the Safety Analysis Report (SAR).

As stated in the NRC IE 'Inspection Manual Part

9800, the intent of 10 CFR 50.59 is to limit the requirement for written safety evaluations to only those facility changes,

tests, and experiments, which could impact the safety of operations.

For a change to a drawing contained in the FSAR to be a change to the facility or procedures as described in the SAR, the change must.be associated with safety and have specific design; operational, or performance requirements specified in the FSAR or the Technical Specifications.

If the drawing change modifies or changes

design, operational, and/or performance requirements approved in the FSAR or Technical Specifications, or could impact plant safety, a

safety evaluation is required."

This definition was not prescriptive and was misinterpreted by.the preparer of the SA for DCN S39677A.

The previous revision of SSP 12.13 (Revision 4) was much more prescriptive; "Typographical errors and editorial changes made to clarify the intent without technically changing the content of the text or drawing do not require a 50.59 evaluation."

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Corrective Ste s Taken And Results Achieved A SE has been performed for DCN S39677A to address the new system alignment.

This"SE concluded that an unreviewed safety question does not exist as a result of the change implemented by DCN S39677A.

Corrective Ste s That

[Have Been Or] Will Be Taken To Prevent Recurrence SPP-9.4, Revision 0 was issued with an effective date of June 30,

1997, superseding SSP-12.13.

The new procedure provides adequate guidance for the identification of FSAR changes that do not require a

SE.

SPP-9.4 specifically defines minor changes that do not need a SE.

SPP-9.4

reads, in part,"...Minor changes are defined as follows:

Corrections of non-numerical typographical errors or editorial changes that do not change the intent (i.e., non-intent changes) in text.

Additions, deletions, or change of a unique identifier and associated changes to affected drawings.

I A part number change (e.g.,

valve disc, diaphragm) without

~an physical changes to the part.

Since the new and old part are identical except for the

number, the plant has not physically changed.

The design documents,

however, must reflect the acceptability of the new part number for configuration and control purposes."

Consequently, any other FSAR changes not meeting the definition above require a SE.

Therefore, using. the current guidance, a written SE would have been required to permit parallel operation of transformers TS1E and TDE.

The current definition of a minor FSAR change is clear and is unlikely to be misinterpreted by SA/SE preparer's.

Training on SPP-9.4, Revision 0,

has been provided to BFN personnel performing 10 CFR 50.59 evaluations..

In order to address the full extent of the condition resulting from the root cause of this violation, all FSAR changes since January 14,

1993, which were E1-3

processed without a SE, will be reviewed to re-confirm that the ultimate objective of the 10 CFR 50.59 process has been satisfied; that is, no changes to the FSAR involving USQs were implemented without prior approval by the NRC.

The existing SAs performed for these changes provide documentation that the changes are safe, that there is no impact on the technical specifications and there is no significant impact on the FSAR.

As a

result of the reviews, analyses and deliberations required to complete the SAs, it is unlikely that any of these changes represent USQs.

FSAR changes since January 14, 1993 for which a SE was not performed will be reviewed for their potential for USQs.

SEs will then be performed for the FSAR changes which involve system alignment changes resulting in operator action or changes in system function.

These evaluations will be completed by March 16, 1998.

4.

Date When Pull Com liance Will Be Achieved TVA has performed a safety evaluation for the change to the FSAR cited in this NOV.

The safety evaluation concluded that the change does not involve an unreviewed safety question.

Therefore,

'TVA is in full compliance.

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ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT {BFN)

UNIT 2 INSPECTION REPORT NUMBER 50-260/97-08 NOTICE OF VIOLATION (NOV)

COMMITMENT FSAR changes since January 14, 1993, for which a SE was not performed will be reviewed for their potential for USQs.

SEs will then be performed for the FSAR changes which involve system alignment changes resulting in operator action or changes in system function.

These evaluations will be completed by March 16, 1998.

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