CNL-14-124, Sampling Plan for NRC Confirmatory Order EA-14-005
| ML14198A399 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/15/2014 |
| From: | James Shea Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CNL-14-124, EA-14-005, IR-13-005 | |
| Download: ML14198A399 (6) | |
Text
Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-14-124 July 15, 2014 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 10 CFR 50.4 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296
Subject:
Sampling Plan for NRC Confirmatory Order EA-14-005
Reference:
Confirmatory Order (NRC Inspection Report 05000259/2013005, 05000260/2013005, and 05000296/2013005), dated May 1, 2014 The above referenced letter from the Nuclear Regulatory Commission (NRC) to Tennessee Valley Authority (TVA), details 20 actions to be taken by TVA and lists the corresponding due dates. Order Requirements V.1.b.ii.7 and V.1.b.ii.8 involve a review of a sample of facility changes to determine whether the changes have been appropriately incorporated into the licensing basis documents. An intermediate action for each of these requirements is to provide the sampling plan to the NRC by July 15, 2014.
The purpose of this letter is to provide TVA's sampling plan to the NRC consistent with the requirements of the Order. The sampling plan is included as an enclosure to this letter.
There are no new regulatory commitments contained in this letter. If you have any questions regarding this response, please contact J. L. Paul, Site Licensing Manager, at (256) 729-2636.
Sincerely~ £d)
J.wL/~
ft7C Vice President, Nuclear Licen Enclosure cc: See Page 2
U.S. Nuclear Regulatory Commission Page 2 July 15, 2014
Enclosure:
Sampling Plan for NRC Confirmatory Order EA-14-005 cc (Enclosure):
NRC Regional Administrator - Region II 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 Sampling Plan for NRC Confirmatory Order EA-14-005
Sampling Plan for NRC Confirmatory Order EA-14-005
Page 1 of 3
METHODOLOGY FOR SELECTING FACILITY CHANGES RELATED TO CONFIRMATORY ORDER EA-14-005 REQUIREMENT V.1.b.ii.7 Nuclear Regulatory Commission (NRC) Confirmatory Order EA-14-005 Requirement V.1.b.ii.7 states: By December 31, 2015, TVA will review a sample of facility changes, based on plant risk and complexity, that have occurred from 2004 to May 2014, to determine whether these changes have been appropriately incorporated into the licensing basis documents. TVAs method of selecting facility changes to be sampled will be provided to the NRC by July 15, 2014. Any identified discrepancies will be dispositioned through the corrective action process. The results of this review will be made available to the NRC.
The intent of this action is to review a sample of the facility changes that were processed in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, Tests, and Experiments, whereas Order Requirement V.1.b.ii.8 is associated with the review of facility changes made outside of the 10 CFR 50.59 process. The sample for this review will be chosen from the population of 10 CFR 50.59 Screenings/Evaluations for facility changes performed from January 2004 through May 2014, inclusive of those changes that required NRC prior approval.
Tennessee Valley Authority is applying the definition of facility change consistent with the Nuclear Energy Institute (NEI) 96.07, Guidelines for 10 CFR 50.59 Evaluations, definition of modification or addition to, or removal from, the facility or procedures that affects: (1) a design function, (2) method of performing or controlling the function, or (3) an evaluation that demonstrates that intended functions will be accomplished. The sources for these documents will be:
Listing from the Business Support Library of all 10 CFR 50.59 screenings between January 2004 and May 2014; All NRC Safety Evaluation Reports (SERs) between January 2004 and May 2014; The License Amendment Requests (LARs) associated with the above SERs; and The Biennial 10 CFR 50.59 Summary Reports.
Step one of the sampling strategy will be to select a random number of documents from the above population. The methodology is based on Military Standard MIL-STD-105E, Sampling Procedures and Tables for Inspection by Attributes, dated May 10, 1989. Section 1.2 of this standard Application, indicates that the sampling plans in the publication are applicable but not limited, to inspection of data and records, and administrative procedures. The size of the sample will be determined using the Level II Single Sampling Plan for Normal Inspection (Ref. Sections 4.6 and 4.9.1, Tables I and II-A of MIL-STD-105E). Level II is normally used and is the midrange of the general inspection methods. The Normal Inspection is also the midrange of the sampling procedures. These qualifiers will be used to determine the sample size from Tables I and II-A of MIL-STD-105E.
Step two will further limit this population to facility changes that were complex and risk significant.
Complex changes will be those that involve multiple disciplines/functional areas. For example, a valve design change which affects not only electrical and/or mechanical design, but also the Loss of Coolant Accident (LOCA) analysis, offsite dose, and operator actions. Risk significant means the change will involve one of the Top Ten risk significant systems according to the Probabilistic Risk Assessment (PRA) model, also including fire risk. The top ten systems are:
High Pressure Coolant Injection (HPCI);
Reactor Core Injection Cooling (RCIC);
Emergency Diesel Generators (EDG);
Sampling Plan for NRC Confirmatory Order EA-14-005
Page 2 of 3
4 kVolt Shutdown Boards (4 kV SDB);
Normal Ventilation; Primary Containment; Feedwater; RHR Service Water (RHRSW); and Core Spray.
These documents will be reviewed by Browns Ferry Nuclear (BFN) Licensing to determine whether these changes have been appropriately incorporated into the licensing basis documents. If any discrepancies are identified, they will be documented, tracked and resolved through the Corrective Action Program. An evaluation of any identified discrepancies will be performed in order to determine whether further review is warranted and recommend additional action, as appropriate.
Tennessee Valley Authority will provide the NRC a summary of the review results, the evaluation of these results, and any additional actions no later than December 31, 2015.
METHODOLOGY FOR SELECTING FACILITY CHANGES RELATED TO CONFIRMATORY ORDER EA-14-005 REQUIREMENT V.1.b.ii.8 NRC Confirmatory Order EA-14-005 Requirement V.1.b.ii.8 states: By December 31, 2015, TVA will review a sample of BFN facility changes, based on plant risk and complexity, accomplished within the last 3 years and processed outside of the 10 CFR 50.59 process to determine whether these changes have been appropriately incorporated into the licensing basis documents. TVAs method of selecting facility changes to be sampled will be provided to the NRC by July 15, 2014.
Any identified discrepancies will be dispositioned through the corrective action process. The results of this review will be made available to the NRC.
The overall sampling strategy will be the same as described above, using a two-step process. The population of documents from which the sample will be chosen will be the facility changes that occurred outside the 10 CFR 50.59 process. This population will be the Applicability Determinations performed from May 1, 2011 through May 31, 2014 that did not result in a 10 CFR 50.59 screening, as well as administrative procedure changes. Tennessee Valley Authority is applying the definition of facility change consistent with the NEI 96-07 definition of modification or addition to, or removal from, the facility or procedures that affects: (1) a design function, (2) method of performing or controlling the function, or (3) an evaluation that demonstrates that intended functions will be accomplished.
The documents reviewed will be selected from the following source documents collected between May 1, 2011 and May 31, 2014:
Emergency Plan changes; Quality Assurance Plan changes; Fire Protection Program changes; Security Plan changes; In-Service Inspection/In-Service Testing Program Plan changes; Independent Spent Fuel Storage Installation changes; Offsite Dose Calculation Manual changes; Commitment changes; and Administrative Procedure changes (NPG-SPPs, BPs, SDPs).
Sampling Plan for NRC Confirmatory Order EA-14-005
Page 3 of 3
Step one of the sampling strategy will be to select a random number of documents from the above population. The methodology is based on Military Standard MIL-STD-105E, Sampling Procedures and Tables for Inspection by Attributes, dated May 10, 1989. Section 1.2 of this standard Application, indicates that the sampling plans in the publication are applicable but not limited, to inspection of data and records, and administrative procedures. The size of the sample will be determined using the Level II Single Sampling Plan for Normal Inspection (Ref. Sections 4.6 and 4.9.1, Tables I and II-A of MIL-STD-105E). Level II is normally used and is the midrange of the general inspection methods. The Normal Inspection is also the midrange of the sampling procedures. These qualifiers will be used to determine the sample size from Tables I and II-A of MIL-STD-105E.
Step two will further limit this population to facility changes that were complex and risk significant.
Complex changes will be those that involve multiple disciplines/functional areas. For example, a valve design change which affects not only electrical and/or mechanical design, but also the LOCA analysis, offsite dose, and operator actions. Risk significant means the change will involve one of the Top Ten risk significant systems according to the PRA model, also including fire risk. The top ten systems are:
High Pressure Coolant Injection (HPCI);
Reactor Core Injection Cooling (RCIC);
Emergency Diesel Generators (EDG);
4 kVolt Shutdown Boards (4 kV SDB);
Normal Ventilation; Primary Containment; Feedwater; RHR Service Water (RHRSW); and Core Spray.
These documents will be reviewed by BFN Licensing to determine whether these changes have been appropriately incorporated into the licensing basis documents. If any discrepancies are identified, they will be documented, tracked and resolved through the Corrective Action Program.
An evaluation of any identified discrepancies will be performed in order to determine whether further review is warranted and recommend additional action, as appropriate. Tennessee Valley Authority will provide the NRC a summary of the review results, the evaluation of these results, and any additional actions no later than December 31, 2015.