IR 05000259/2011011

Browns Ferry, Units 1, 2 and 3 - Response to an Apparent Violation in Inspections Report 05000259-11-011, 05000260-11-011, 05000296-11-011; EA-11-252

ML11362A379
Person / Time
Site:	Browns Ferry
Issue date:	12/19/2011
From:	Shea J W Tennessee Valley Authority
To:	Document Control Desk, NRC/RGN-II
References
EA-11-252 IR-11-011
Download: ML11362A379 (6)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402December 19, 201110 CFR 2.201ATTN: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, D.C. 20555-0001Browns Ferry Nuclear Plant, Units 1, 2, and 3Facility Operating License Nos. DPR-33, DPR-52, and DPR-68NRC Docket Nos. 50-259, 50-260, and 50-296Subject: Response to an Apparent Violation in Inspection Report 05000259/2011011,0500026012011011, 0500029612011011; EA-1 1-252Reference: Letter from NRC to TVA, "Browns Ferry Nuclear Plant -NRC InspectionProcedure 95003 Supplemental Inspection Report 05000259/2011011,05000260/2011011, and 05000296/2011011 (Part 1)," dated November 17, 2011In accordance with the reference letter, the Tennessee Valley Authority (TVA) is required tosubmit a response to the Notice of Violation EA-1 1-252 within 30 days of the date of the letterwhich transmitted the notice of violation, i.e., by December 17, 2011. BecauseDecember 17, 2011 fell on a Saturday, TVA's response is being submitted onDecember 19, 2011. The TVA response to this notice of violation is provided in the enclosure inaccordance with 10 CFR 2.201.There are no new regulatory commitments contained in this response. Should you have anyquestions concerning this submittal, please contact Tom Hess at (423) 751-3487.R e s u l l y , L naeCorporate Nuclear Licensing U.S. Nuclear Regulatory CommissionPage 2December 19, 2011

Enclosure:

Response to an Apparent Violation in Inspection Report 05000259/2011011,05000260/2011011, 05000296/2011011; EA- 11-252cc (Enclosure):NRC Regional Administrator -Region IINRC Director, Office of EnforcementNRC Senior Resident Inspector -Browns Ferry Nuclear PlantNRC Project Manager -Browns Ferry Nuclear Plant ENCLOSURETennessee Valley AuthorityBrowns Ferry Nuclear Plant, Units 1, 2, and 3Response to an Apparent Violation in Inspection Report 05000259/2011011,05000260/2011011, 05000296/2011011; EA-11-252 Response to an Apparent Violation in Inspection Report 0500025912011011,0500026012011011, 05000296/2011011; EA-1 1-252Restatement of ViolationTitle 10 CFR 50.9 requires, in part, that information provided to the Commission by anapplicant for a license or by a licensee or information required by statute or by theCommission's regulations, orders, or license conditions to be maintained by theapplicant or the licensee shall be complete and accurate in all material respects.Contrary to the above, on January 6, 1997, TVA provided information to theCommission that was not complete and accurate in all material respects. Specifically, ina letter dated October 7, 1996, the NRC asked TVA to further consider and respond toquestions about whether valves FCV-74-52 and FCV-74-66 had a redundant safetyfunction to close to allow operation of the suppression pool cooling mode of the RHRSystem. In a letter dated January 6, 1997, TVA responded that "Closure of valves FCV-74-52 and FCV-74-66 is not required by plant procedures to operate the RHR system inthe suppression pool cooling mode. Therefore, these valves have no 'redundant' safetyfunction and will not be included in the GL-89-10 program." This information wasinaccurate because the FCV-74-52 and FCV-74-66 valves do have a safety function toshut to operate the RHR system in the suppression pool cooling mode as described inEOI Appendix-17A, "RHR System Operation Suppression Pool Cooling," and shouldtherefore have been included in Browns Ferry's GL 89-10 MOV monitoring program.Additionally, The NRC identified that incomplete and inaccurate information was alsoprovided in a letter dated May 5, 2004. This letter stated that "TVA's review anddocumentation of the design basis for the operation of each Unit 1 MOV within thescope of the GL 89-10 program, the methods for determining and adjusting its switchsettings, testing, surveillance and maintenance are the same as with the Units 2 and 3program."This information was material to the NRC because it was used, in part, as the basis fordetermining that valves FCV-74-52 and FCV-74-66 did not meet the conditionsnecessary that would require them to be in Browns Ferry's GL 89-10 MOV monitoringprogram. The issue was preliminarily determined to be an apparent violation of 10 CFR50.9 (AV 05000259, 260, 296/2011011-02; Inaccurate Information Provided RegardingScoping of Motor Operated Valves in the Generic Letter 89-10 Program). This issuewas entered into BFN's CAP as SR 435463, "95003 -PER 430439 documented thatUnits 1, 2, and 3 RHR Outboard Injection Valves, FCV-74-52 and FCV-74-66, Shouldhave been Included in the Scope of the GL 89-10 Program. The Purpose of this SR isto Assess the Technical Basis and Adequacy of the NRC Correspondence for the GL89-10 Scope removal of These Valves in the mid 1990's."BackgroundTennesse Valley Authority (TVA) incorrectly determined that flow control valves FCV-74-52 andFCV-74-66 were "passive" based on operating in their safety position during normal alignment.Additionally, TVA failed to identify that FCV-74-52 and FCV-74-66 are required to be closed toenable Residual Heat Removal (RHR) to operate to the suppression pool cooling mode, perEmergency Operating Instruction (EOI) Appendix-1 7A.E- 1 of 3 Response to an Apparent Violation in Inspection Report 05000259/2011011,05000260/2011011, 0500029612011011; EA-1 1-252By letter dated January 6, 1997, TVA responded to NRC inspector follow-up item50-260, 296/95-19-01 regarding the reduced scope of motor-operated valves (MOVs) in theNRC Generic Letter 89-10, "Safety-Related Motor-Operated Valve Testing and Surveillance,"program for Browns Ferry Nuclear Plant (BFN) Units 2 and 3. This letter stated in part that"Closure of valves FCV-74-52 and FCV-74-66 is not required by plant procedures to operate theRHR system in the suppression pool cooling mode.. ." As a result, FCV-74-52 and FCV-74-66were removed from the GL 89-10 program in 1997, in accordance with Supplement 1 toGL 89-10.As identified during the root cause analysis being conducted to address the issues associatedwith the failure of FCV-74-66 in BFN Unit 1, TVA discovered that the statement "Closure ofvalves FCV-74-52 and FCV-74-66 is not required by plant procedures to operate the RHRsystem in the suppression pool cooling mode. .." was inaccurate. Specifically, the revision ofthe EOI, Appendix 17A, that was in place in January 1997 included a step to verify that theFCV-74-52 or FCV-74-66 valve was closed as part of performing the steps to place the RHRsystem in the suppression pool cooling mode. As required by 10 CFR 50.9(b), TVA providedwritten notification to the NRC by letter dated October 20, 2011, acknowledging the inaccuracyof its January 6, 1997 letter. Additionally, TVA provided written notification to the NRC by letterdated December 19, 2011, acknowledging the inaccuracy of its May 5, 2004 letter.With respect to FCV-74-52 and FCV-74-66 and the GL 89-10 program, TVA will implement thefollowing actions:" Add 1, 2, 3 -FCV-74-52 and 1, 2, 3 -FCV-74-66 to the GL 89-10 program.* Develop or revise an existing procedure to specifically provide the criteria fordetermining GL 89-10 program scope, including active/passive classification.Reason for the ViolationThe reasons for this violation of 10 CFR 50.9 are:STVA failed to apply adequate technical rigor to the review process for regulatorysubmittals. The responsible licensing engineer was requested by a reviewer of theJanuary 1997 submittal to verify the statement regarding closure of valves FCV-74-52and FCV-74-66. Verification was done through verbal confirmation from Engineeringwithout documentation supporting the conclusion.F VA procedures did not contain sufficient details governing the verification process forregulatory submittals. TVA procedures in place at the time of the 1997 letter onlyprovided guidance on acceptable methods of verification. In addition, the procedurestated that method of verification remained at the discretion of the technical lead; not theresponsible licensing engineer.E- 2 of 3 Response to an Apparent Violation in Inspection Report 05000259/2011011,05000260/2011011, 0500029612011011; EA-1 1-252TVA personnel assigned to the BFN Unit 1 restart licensing failed to follow proceduresgoverning the verification process for regulatory submittals. The information provided inthe May 5, 2004 letter related to BFN Unit 1 was verified to the extent required to ensurethe BFN Unit 1 valves were described in a manner equivalent to the BFN Units 2 and 3valves. As stated in the 2004 letter, the basis for excluding the BFN Unit 1 valves fromthe GL 89-10 program was the same as the BFN Units 2 and 3 valves.Corrective Steps That Have Been Taken and Results AchievedAs stated above, TVA provided written notification to the NRC by letter dated October 20, 2011,acknowledging the inaccuracy of its January 6, 1997 letter, in accordance with 10 CFR 50.9(b).Additionally, TVA provided written notification to the NRC by letter dated December 19, 2011,acknowledging the inaccuracy of its May 5, 2004 letterProcedural requirements in TVA procedure BP-213, "Managing TVA's Interface with NRC,"governing the verification of information contained in NRC submittals were enhanced in 2002.These enhancements, included the following, are contained in the current revision of BP-213:* Designating oversight responsibility for the submittal verification process to Licensing." Specifying which NRC submittals require verification.* Describing which types of statements in NRC submittals require verification.* Providing detailed requirements for verification packages.With respect to the failure of BFN Unit 1 restart licensing personnel to follow the proceduregoverning the verification process for regulatory submittals (i.e. BP-213), procedure use andadherence has since been reinforced as one of TVA's fundamental human performance tools.Management expectations regarding procedure use and adherence are communicated regularlythrough TVA Nuclear corporate and site communications and are further reinforced throughTVA's Nuclear Fleet Focus Handbook.Corrective Steps That Will Be Taken to Avoid Future ViolationsAll identified corrective actions to avoid future violations have been implemented.Date When Full Compliance Will Be AchievedFor the 10 CFR 50.9 violation described in EA-1 1-252, TVA achieved full compliance with theOctober 20, 2011 and December 19, 2011 NRC notification letters.E-3 of 3