ML20236R856
| ML20236R856 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/17/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8711240068 | |
| Download: ML20236R856 (6) | |
Text
_,x;
-g{
I f@
TENNESSEE VALLEY AUTHORITY CH ATTANOOG A, TENNESSEE 37401.
.J SN'157B Lookout Place
(
NOV 171987 s;c t U.L S. Nuclear Regulatory Corrmission
' ATTNi. Document' Control-Desk
~ Hash 1rigton' : D.C.
20555 i
j a
1' Gentlemen:
l Inithe matter'of--.
)
Docket Nos. 50-259
- Tennessee Valley Authority
)
50-260
.)
50-296 e
- BROWNS. FERRY NUCLEAR PLANT.(BFN). UNITS 1 2, AND 3 - NRC-0IE INSPECTION REPORT 4
- NOS. 50-259/87-30, 50-260/87-30, AND 50-296/87 RESPONSE TO NOTICE OF I
DEVIATION 4
4 7
l, Enclosed-.is TVA's' response to the letter from G. G. Zech to S. A. White dated September'29, 1987,.which transmitted IE Inspection Report Nos. 50-259/87-30,
. 50-260/87-30,'and 50-296/87-30 for TVA's'BFN-units 1, 2, and 3.
.This report-
' cited TVA'with one deviation. provides TVA's description of correctiveLactions and the completion dates. -A list of commitments is provided in' enclosure 2.
An extension of the response due date to November'17,f1987.was agreed to in a conversation with A. Ignatonis on November:16, 1987.
Pl' ease refer any questions to M.'J. May, Manager of Site Licensing, Browns
. Ferry,;(205) 729-3566.
~
Very truly yours, 1
TENNESSEE V LLEY AUTHORITY 1
R.
- ridley, irector Nuclear Licensing and Regulatory Affairs L
' Enclosures cc: :See page'2 pr j,,
L' -
8711240068 871117 r
PDR. ADOCK 05000259 s \\
P 0
PDR i
k
_. I...
si'
, U.S.-Nuclear Regulatory Commission NOV 171987 cc (Enclosure):
Mr. G. G. Zech, Assistant Director Regional Inspections Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory. Commission Region.II 101 Marietta'St., NW, Suite 2900 Atlanta, Georgia 30323 Mr. J. A. Zwolinski, Assistant Director for Projects Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Commission 43S0 East-West Highway EWW 322
'Bethesda, Maryland 20814 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 2, P.O. Box 311 Athens, Alabama 35611 i
i lL
pg '
j L
l ENCLOSURE 1 I
NRC INSPECTION REPORT N05, i
i 50-259/87-30, 50-260/87-30, 50-296/87-30 LETTER FROM G. G. ZECH TO S. A. WHITE DATED SEPTEMBER 29, 1987
' Deviation The licensee informed'NRC in its letter to Dr. J. Nelson Grace, Regional Administrator for NRC Region II, dated May 20, 1986, that future changes to the Final' Safety Analysis Report (FSAR) would be formally evaluated and justified before revising the FSAR and that the justifications would be available for. review.
Contra'ry to the above, the licensee made changes to the FSAR in Amendment 5,
' dated July 22, 1987, which were not. formally evaluated and documented for review. The following examples were identified:
1.
Paragraph 2.2 was changed to delete a commitment to periodically examine
.the site description portion of the FSAR and to maintain a reasonable representation of the area population and land use.
2.
Paragraph ~13.3.1 was changed to. delete a commitment to schedule training visits to other operating facilities for selected supervisors.
3.
Paragraph 2.6.2.1 was changed to delete collection of" heavy particle fallout and rainwater samples at the local and perimeter environmental monitoring stations.
'This deviation is applicable to all three units.
Discussion of FSAR Revisions 10 CFR 50.71(e) requires revisions to the FSAR no less frequently than annually-to ensure..the FSAR contains the latest material developed.
The BFN
. site procedure governing FSAR changes requires that changes be evaluated and justified. This procedure was revised to implement the commitment made by the May 20,.1986 letter to NRC referred to above and to formally evaluate and justify changes.
This evaluation is implemented by performing a screening in accordance with 10 CFP 50.59 cn all changes affecting the intent of the FSAR.
Typographical errors and editorial text (non-intent) changes are exempt from this screening.
Hardware changes and plant procedure changes already have a 10 CFR 50.59 screening performed as part of their origination.
Revisions due to changes in technical specifications are formally evaluated and justified by their safety evaluation report.
Programmatically, the difficult part is tying
, all these changes together as a reviewable package with supporting
. documentation.
l
eqp 1
a
'l; 20
~
[k.y '
g -
6 d
, tin theispecific. instances cited, examples (1) and.(2) were changed as y,
- non-intent changes and_ example (3) was as'a result.of a technical specification change. As.such,' all of the changes were evaluated against
- 2 110-CFR 50.59feriteria,!but:the FSAR update procedure-did not-require a
,w.
jdetailed) justification'forc each change 1to the FSAR.
The FSAR update procedure t
- isLbeingjrevisedias discussed below.
I.
Corrective Steps Which Have~Been Taken and Results Achieved I
- a
~ ' INr LTh' lindividual' examples of the' deviation have been reviewed and e
. dispositioned as.follows.
n:
Example'l.
The' change lto' delete a' commitment to periodically examine the
~
- site description portion of the FSAR and to maintain a reasonable
" representation of:the area population and land use was evaluated and found to-befunjustified~.
1*1 4
e~
1 Example 2.
The changet o' delete the commitment for scheduling training t
visitstfor engineers:and supervisors to other facilities was evaluated and-is. justified. by the following. This statement from the original FSAR was intended:to allow plantiengineering and supervisors to gain operating-experience-before'the initial startup..Since that time, the availability of.a site; specific simulator and an accredited training program have made 4these' training visits unnecessary. _The. ongoing program for TVA technical Hf staff:and: managers hat an orientation and an~ advanced phase.
The 61 TorientationLphase'= provides indoctrination as' discussed in ANSI N-18.1 and u;.
> ANSI;N-18.7.
The~ advanced phase;has in-depth training for individuals who
- require :significant exposure to plant operations and successful completion leadsLto'a simulator certification.. Additionally, overall programs and methods are periodically' reviewed by the Institute of Nuclear Power Operations (INPO).
i
' Exampl e ' '3.
.The change: involving collection of fallout and rainwater samples;is' justified because the current requirements for radiological
-environment 1' monitoring are as specified in the technical specifications
"+
1
-and the. Radiological: Effluent Manual (REM). These requirements were formally evaluatedLby NRC in the safety evaluation report supporting
^
Technical Specifications; Amendments 132, 128, and 103 of February 5, 11987.. This amendment changed the technical specifications of all three BFN units'to comply with 10 CFR 50 Appendix I, Section V.
This change
' brought the FSAR.into' agreement with the technical specifications, n
{
'l nI
y.
c 2; Correct'ive Steps Which Will Be Taken To Avoid Further Deviations The statement' requiring a periodic examination of the BFN site description to provide a reasonable representation of area population and land use will'be reinserted'in FSAR paragraph 2.2 at the next annual FSAR update which is due July 22, 1988.
'The rest of the 1987 FSAR update will be reviewed to ensure that proper justifications exist for the changes made to the FSAR.
This review will be completed.by December 31, 1987, and any changes that are not justifiable will be corrected in the 1988 FSAR update.
l The site procedure for FSAR revisions will be revised by January 22, 1988, the cutoff date for the next annual FSAR update, to require a formal justification for all' changes in addition to the screening evaluation for 10 CFR 50.59. concerns.
It should be noted that typographical errors and editorial text changes do not require the 10 CFR 50.59 screening evaluation but will require a justification.
This procedure will be used d
E or the 1988 FSAR update.
f TVA will, review the. update process and evaluate the adequacy of this process for updating chapter 2.
TVA will provide information regarding this evaluation by February 15, 1988.
-3.
Date When Full Compliance Will Be Achieved Full. compliance will be achieved with the submittal of the next annual FSAR update on' July 22, 1988.
l t
9 li__u ___.
i
ry77nn~n:
y ne -
jf?h il*n?w n
ee,,
+
+
y:<-
Ng
+
'j NRC-INSPECTION REPORT NOS.
50-259/87-30,,50-260/87-30,' 50-296/87-30 LETTER FROM G; G. ZECH T0 S. A:. WHITE DATED. SEPTEMBER 29, 19871 L*
I.
The 1987 FSAR! update' will: be reviewed by December 31, 1987, to ensure t
.properijustification for the changes.
l2DLTVA'will? provide'aLfollowuplettertoNRCbyFebruary-15,1988, providingL i
11nformation regarding'the' adequacy of the process'for updating FSAR pt b LChapter 2.:
+
3.LTheitteprocedureforFSARupdates.w1111 be revised by January 22, 1988, (to require a: formal justification for~alll changes.
i
)
"4L Any unsubs'tantiated changes that-areJfound to have been made in 1987 FSAR.
' update will be: corrected inLthe.1988 FSAR update which is due July 22, 1988.
- 5. :The 'tatement requiring a periodic: examination of the site description to.
s provide' a reas'onable representation of. area population and land use will be reinserted in FSAR paragraph 2.2 at the.next annual FSAR update which is due. July 22, 1988.
'i ;'
4
' ma e
4 i '
g.g 9
._______._Q