ML20207T376
| ML20207T376 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/04/1987 |
| From: | Zech G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | White S TENNESSEE VALLEY AUTHORITY |
| References | |
| EA-86-056, EA-86-56, IEC-80-18, NUDOCS 8703230499 | |
| Download: ML20207T376 (4) | |
Text
.
MAR 4 187 a.
Tennessee Valley Authority gAtTN:.Mr. S.'A. White
~
Manager of. Nuclear Power 6N 38A Lookout Place 1101 Market Street Chattanooga, TN-37402-2801 Gentlemen:
2
SUBJECT:
REPORT NOS. 50-259/EA 86 56, 50-260/EA 86-56, AND 50-296/EA 86-56 Thank you for:'your response of 0ctober 8,1986, to our Notice of Violation and Proposed Imposition of Civil Penalties issued on September 8,1986, concerning activities conducted at your Browns Ferry facility.
In our evaluation of your response, we have assumed that your statement that TVA does not contest the violation meant that you admit the viol hion. With that assumption, we have evaluated your response and found that it meets the requirement of 10 CFR 2.201.
We will examine the -implementation of you'r corrective actions to correct Viola-tions I.A,- I.B,-and I.C during future inspections.
After careful consideration of the bases for your denial of Violation II, we have concluded, for the ~ reasons presented in the enclosure to the letter, that the violation occurred as - stated in the Notice of Violation.
Therefore, in accordance with 10 CFR 2.201(a), please submit to this office within 30 days of
_.the date of this letter a written statement describing steps which have been taken to correct Violation II and the results achieved, corrective steps which will be taken to avoid further violations, and the date when full compliance will be achieved. Also, include in your corrective action the root cause of your initial incorrect 10 CFR 50.59 interpretation.
The response directed by this letter is not subject to the clearance procedure of the Office of Management and Budget issued under the Paperwork Reduction Act, PL 96-511.
We appreciate your cooperation in this matter.
Sincerely, ORIGINAL SIGNED By GARY G. ZECH Gary G. Zech, Assistant Director Regional Inspections Division of TVA Projects Office of Special Projects
Enclosure:
(See page 2) 8703230499 870304 PDR ADOCK 05000259 G
PDR Il
MAR 4 1987 Tennessee Valley Authority 2
Enclosure:
' Staff Comments on Denia; of Violation II cc w/ enc 1:
R' P. Pomrehn,. Site Director
.p Browns Ferry Nuclear' Plant Jt(L.'Gridley, Director
-Nuclear-Safety and Licensing LK. W. Cantrell, Acting Director Nuclear Engineering pf J. May, Site Licensing Manager g
-bec w/ enc 1:
G. G. Zech, RII yk'G.- Keppler, OSP LSf'D. Ebneter, OSP tJf" A. Zwolinski, OSP
.tBf D. Liaw, OSP 4rIR.Connelly,0IA
$P. G. Gears, NRR K. P. Barr, RII FNRC Resident Inspector NRC Document Control Desk State of Alabama l
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MAR 419r7 ENCLOSURE STAFF COMMENTS ON DENIAL OF VIOLATION II After a careful review of your October 8,1986, response to the 10 CFR 50.59 violation (Item II) and the review of our records (i.e., NRC inspection reports and IE Circular No. 80-18), we disagree with your conclusion that this violation did not occur. Based on the reasons provided below, we conclude that a 10 CFR 50.59 violation did indeed occur as stated in the Notice of Violation issued on September 8, 1986.
The licensee believes that a change in acceptable closure time of secondary containment isolation dampers from two seconds as specified in Section 5.3.4.2 of the FSAR to ten seconds did not constitute a change in the facility within the scope of 10 CFR 50.59 regulation.
10 CFR 50.59(a) allows the holder of a licensee to make changes in the facility as described in.the FSAR without prior Commission approval unless it involves a change to _ the Technical specifications or is an unreviewed safety question. While we have eventually agreed with the licensee's determination that the change in damper closure time did not consti-
.tute an unreviewed safety question, it should be pointed out that at the time the change in damper operability was determined to be acceptable by the licensee's plant staff (internal plant memorandum of November 25, 1985),. no determination was made by the licensee via an administrative procedure on whether the change involved an unreviewed safety question.
The fact of the matter is l
that no Unreviewed Safety Question Determination (USQD) was initiated and pre-pared for this change per the requirements of Standard Practice 17.18 until December 9 or 10, '1985.
The licensee's USQD report which includes a safety evaluation for the proposed change is used as a mechanism to determine whether the change involves an unreviewed safety question. It was on December 10, 1985, when the USQD was reviewed by the Plant Operations Review Committee and approved by the Plant Manager in which it was concluded by the licensee that the subject change did not constitute an unreviewed safety question. The NRC's concurrence with the same conclusion was not reached until March 28, 1986, after NRR's review of the TVA's January 23, 1986 submittal covering the revised FSAR fuel handling accident with longer secondary containment isolation damper closure times.
As discussed in the licensee's response, the secondary containment dampers became a safety issue when it was found that they failed to comply with the system design basis as discussed in Section 5.3.4.2 of the FSAR.
Paraphrased, this section, the Chapter 14 refueling accident analysis, as well as the basis for the refueling zone radiation monitor trip setpoint contained in the basis for Section 3.2 of the plant Technical Specifications describes the system response to a refueling accident as follows:
the normal ventilation dampers close and the Standby Gas Treatment System (SGTS) starts in such a fashion that none of the activity released during the refueling accident leaves the Reactor Building (at ground level) but rather all the activity is processed through the SGTS and released via the plant's 600 foot stack.
l
MAR 4 1987 Enclosure 2
When a system ' is found to be in nonconformance with the FSAR and. Technical Specifications, at a time when it is required to be operable, two options exist.
First, the system must be declared inoperable and any. required Technical Speci-fication actions must be taken until it is restored to the configuration which matches the pre-existing, approved design basis. Alternately, the noncompliance may be evaluated and found to be acceptable as is. Should this second option be selected, no' change would be made to the system or components' as found condi-tion, however, a change to the system as described in the FSAR would have been deemed acceptable and made by default. The licensee is required by 10 CFR 50.59 to determine whether an unreviewed safety question is involved prior to changing the facility as described in the FSAR. After the licensee discovered the noncon-formance, it was evaluated and judged acceptable without determining whether this involved an unreviewed safety question.
Furthermore, as stated in IE Circular No. 80-18: 10 CFR 50.59 Safety Evaluations for. Changes to Radioactive Waste Treatment Systems, which is applicable to this issue, a safety evaluation is required to meet the provisions of 10 CFR 50.59 and any change must be reported to the NRC as required by 10 CFR 50.59(b) if compo-nent functions are altered.
In the above case, the secondary containment isolation damper function was altered through the acceptance of longer damper closure times.
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