ML11362A379
| ML11362A379 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/19/2011 |
| From: | James Shea Tennessee Valley Authority |
| To: | Document Control Desk, NRC/RGN-II |
| References | |
| EA-11-252 IR-11-011 | |
| Download: ML11362A379 (6) | |
See also: IR 05000259/2011011
Text
Valley Authority, 1101 Market Street, Chattanooga, Tennessee
37402 December 19, 2011 10 CFR 2.201 ATTN: Document Control Desk U.S. Nuclear Regulatory
Commission
Washington, D.C. 20555-0001
Browns Ferry Nuclear Plant, Units 1, 2, and 3 Facility Operating
License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296 Subject: Response to an Apparent Violation
in Inspection
Report 05000259/2011011, 0500026012011011, 0500029612011011;
EA-1 1-252 Reference:
Letter from NRC to TVA, "Browns Ferry Nuclear Plant -NRC Inspection
Procedure
95003 Supplemental
Inspection
Report 05000259/2011011, 05000260/2011011, and 05000296/2011011 (Part 1)," dated November 17, 2011 In accordance
with the reference
letter, the Tennessee
Valley Authority (TVA) is required to submit a response to the Notice of Violation
EA-1 1-252 within 30 days of the date of the letter which transmitted
the notice of violation, i.e., by December 17, 2011. Because December 17, 2011 fell on a Saturday, TVA's response is being submitted
on December 19, 2011. The TVA response to this notice of violation
is provided in the enclosure
in accordance
with 10 CFR 2.201.There are no new regulatory
commitments
contained
in this response.
Should you have any questions
concerning
this submittal, please contact Tom Hess at (423) 751-3487.R e s u l l y , L n aeCorporate
Nuclear Licensing
U.S. Nuclear Regulatory
Commission
Page 2 December 19, 2011 Enclosure:
Response to an Apparent Violation
in Inspection
Report 05000259/2011011, 05000260/2011011, 05000296/2011011;
EA- 11-252 cc (Enclosure):
NRC Regional Administrator
-Region II NRC Director, Office of Enforcement
NRC Senior Resident Inspector
-Browns Ferry Nuclear Plant NRC Project Manager -Browns Ferry Nuclear Plant
ENCLOSURE Tennessee
Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Response to an Apparent Violation
in Inspection
Report 05000259/2011011, 05000260/2011011, 05000296/2011011;
Response to an Apparent Violation
in Inspection
Report 0500025912011011, 0500026012011011, 05000296/2011011;
EA-1 1-252 Restatement
of Violation Title 10 CFR 50.9 requires, in part, that information
provided to the Commission
by an applicant
for a license or by a licensee or information
required by statute or by the Commission's
regulations, orders, or license conditions
to be maintained
by the applicant
or the licensee shall be complete and accurate in all material respects.Contrary to the above, on January 6, 1997, TVA provided information
to the Commission
that was not complete and accurate in all material respects.
Specifically, in a letter dated October 7, 1996, the NRC asked TVA to further consider and respond to questions
about whether valves FCV-74-52
and FCV-74-66
had a redundant
safety function to close to allow operation
of the suppression
pool cooling mode of the RHR System. 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 in the suppression
pool cooling mode. Therefore, these valves have no 'redundant'
safety function and will not be included in the GL-89-10 program." This information
was inaccurate
because the FCV-74-52
and FCV-74-66
valves do have a safety function to shut to operate the RHR system in the suppression
pool cooling mode as described
in EOI Appendix-17A, "RHR System Operation
Suppression
Pool Cooling," and should therefore
have been included in Browns Ferry's GL 89-10 MOV monitoring
program.Additionally, The NRC identified
that incomplete
and inaccurate
information
was also provided in a letter dated May 5, 2004. This letter stated that "TVA's review and documentation
of the design basis for the operation
of each Unit 1 MOV within the scope of the GL 89-10 program, the methods for determining
and adjusting
its switch settings, testing, surveillance
and maintenance
are the same as with the Units 2 and 3 program." This information
was material to the NRC because it was used, in part, as the basis for determining
that valves FCV-74-52
and FCV-74-66
did not meet the conditions
necessary
that would require them to be in Browns Ferry's GL 89-10 MOV monitoring
program. The issue was preliminarily
determined
to be an apparent violation
of 10 CFR 50.9 (AV 05000259, 260, 296/2011011-02;
Inaccurate
Information
Provided Regarding Scoping of Motor Operated Valves in the Generic Letter 89-10 Program).
This issue was entered into BFN's CAP as SR 435463, "95003 -PER 430439 documented
that Units 1, 2, and 3 RHR Outboard Injection
Valves, FCV-74-52
and FCV-74-66, Should have been Included in the Scope of the GL 89-10 Program. The Purpose of this SR is to Assess the Technical
Basis and Adequacy of the NRC Correspondence
for the GL 89-10 Scope removal of These Valves in the mid 1990's." Background
Tennesse Valley Authority (TVA) incorrectly
determined
that flow control valves FCV-74-52
and FCV-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 to enable Residual Heat Removal (RHR) to operate to the suppression
pool cooling mode, per Emergency
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 1-252 By letter dated January 6, 1997, TVA responded
to NRC inspector
follow-up
item 50-260, 296/95-19-01
regarding
the reduced scope of motor-operated
valves (MOVs) in the NRC 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 the RHR system in the suppression
pool cooling mode.. ." As a result, FCV-74-52
and FCV-74-66 were removed from the GL 89-10 program in 1997, in accordance
with Supplement
1 to GL 89-10.As identified
during the root cause analysis being conducted
to address the issues associated
with the failure of FCV-74-66
that the statement "Closure of valves FCV-74-52
and FCV-74-66
is not required by plant procedures
to operate the RHR system in the suppression
pool cooling mode. .." was inaccurate.
Specifically, the revision of the EOI, Appendix 17A, that was in place in January 1997 included a step to verify that the FCV-74-52
or FCV-74-66
valve was closed as part of performing
the steps to place the RHR system in the suppression
pool cooling mode. As required by 10 CFR 50.9(b), TVA provided written notification
to the NRC by letter dated October 20, 2011, acknowledging
the inaccuracy
of its January 6, 1997 letter. Additionally, TVA provided written notification
to the NRC by letter dated 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
the following
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 for determining
GL 89-10 program scope, including
active/passive
classification.
Reason for the Violation The reasons for this violation
of 10 CFR 50.9 are: STVA failed to apply adequate technical
rigor to the review process for regulatory
submittals.
The responsible
licensing
engineer was requested
by a reviewer of the January 1997 submittal
to verify the statement
regarding
closure of valves FCV-74-52 and FCV-74-66.
Verification
was done through verbal confirmation
from Engineering
without documentation
supporting
the conclusion.
F VA procedures
did not contain sufficient
details governing
the verification
process for regulatory
submittals.
TVA procedures
in place at the time of the 1997 letter only provided guidance on acceptable
methods of verification.
In addition, the procedure stated that method of verification
remained at the discretion
of the technical
lead; not the responsible
licensing
engineer.E- 2 of 3
Response to an Apparent Violation
in Inspection
Report 05000259/2011011, 05000260/2011011, 0500029612011011;
EA-1 1-252 TVA personnel
assigned to the BFN Unit 1 restart licensing
failed to follow procedures
governing
the verification
process for regulatory
submittals.
The information
provided in the May 5, 2004 letter related to BFN Unit 1 was verified to the extent required to ensure the BFN Unit 1 valves were described
in a manner equivalent
to the BFN Units 2 and 3 valves. As stated in the 2004 letter, the basis for excluding
the BFN Unit 1 valves from the GL 89-10 program was the same as the BFN Units 2 and 3 valves.Corrective
Steps That Have Been Taken and Results Achieved As 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 letter Procedural
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 procedure governing
the verification
process for regulatory
submittals (i.e. BP-213), procedure
use and adherence
has since been reinforced
as one of TVA's fundamental
human performance
tools.Management
expectations
regarding
procedure
use and adherence
are communicated
regularly through TVA Nuclear corporate
and site communications
and are further reinforced
through TVA's Nuclear Fleet Focus Handbook.Corrective
Steps That Will Be Taken to Avoid Future Violations
All identified
corrective
actions to avoid future violations
have been implemented.
Date When Full Compliance
Will Be Achieved For the 10 CFR 50.9 violation
described
in EA-1 1-252, TVA achieved full compliance
with the October 20, 2011 and December 19, 2011 NRC notification
letters.E-3 of 3