ML18031A707
| ML18031A707 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/12/1986 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8608210071 | |
| Download: ML18031A707 (5) | |
Text
TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401
-'N 157B Lookout Place 866SII is aa: sd U.S. Nuclear Regulatory Commission Region II ATTN:
Dr. J.
Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Dear Dr. Grace:
BROWNS FERRY NUCLEAR PLANT UNITS 1 2
AN 3 NRC-OIE REGION II INSPECTION REPORT 50-259/86-06,
-260/86-06, 296/86-0 REVISED RESPONSE Please refer to R. L. Gridley's letter to you dated May 1, 1986 which provided our response to Inspection Report 86-06 for Browns Ferry.
Enclosed is a revised response to Violation 1.b.
This revision reflects our commitment to ensure that our activities are conducted in accordance with documented.
instructions, and specifically that this instruction is adequate for controlling the removal of fire protection equipment from service.
If you have any questions, please get in touch with M. J.
May at (205) 729-3566.
To the best of my knowledge, I declare the statements contained herein are complete and true, Very truly yours, TENNESSE VALLEY AUTHORITY
~
~
J.
A. Domer, Assistant Director Nuclear Safety and Licensing Enclosure cc:
Mr. James Taylor, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington-,
D.C.
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An Equal Opportunity Employer
REVISED RESPONSE NRC INSPECTION REPORT NOS.
50-259/86-06, 50-260/86-06, AND 50-296/86-06 JOHN A. OLSHINSKI'S LETTER TO S.
A. WHITE DATED APRIL 1, 1986
., Item 1 Technical Specification 6.3 requires that detailed written procedures, including applicable checkoff lists, for surveillance and testing requirements shall be prepared,
- approved, and adhered to; and temporary changes to a procedure may be made which do not change the intent of the approved procedure.
Item l.b.
Contrary to the above, this requirement was not met for the following examples:
b.
Temporary changes, termed nonintent changes, were made to SI 4.11.A.l-e which were intent changes.
Browns Ferry Standard Practice.1.3 defines intent changes as changes in scope, technique, or sequential order of instruction steps that would affect the result of nuclear safety.
A nonintent change processed January 29,
- 1986, changed 38 valves to the procedure changing a majority of the steps in the procedure.
The changes to the isolation valves affected the number of fire protection zones removed from service at one time.
Although the fire protection engineer reviewed the original procedure, the nonintent change which affected the fire protection system was not reviewed prior to implementing the change.
This is a Severity Level IV violation (Supplement I) and is applicable to all units.
l.
Admission or Denial of the Alle ed Violation TVA admits the violation.
2.
Reasons for the Violation Surveillance Instruction (SI) 4.11.A.l-e, Testing of Fixed Water Nozzles for Blockage, incorrectly shoWed the deluge valves as the isolation valves.
The nonintent change performed on January 29, 1986 was generated to correct. the procedure.
We agree that the change was incorrectly categorized as nonintent in that the scope of the instruction was expanded in the number of fire protection zones affected..
In addition, form BF-31, which is used in conjunction with the SI for controlling the removal of fire protection equipment from service, did not identify the isolation valves for isolating the system and only identified three of the four zones.
The indivt.dual who incorrectly classified this
Item l.b..(continued) revision as a nonintent change and his supervisor who approved the nonintent change made an incorrect evaluation.
Their evaluation appeared to be based on the assumption that the personnel involved in physi, cally isolating the zones were always aware of the correct valves to close; therefore, the number of fire protection zones were not actually affected.
On this assumption, they classified the revision. as a nonintent change.
Their assumption which we believe to be true is, however, not acceptable.
Our activities must be prescribed by correct.
documented instructions and procedures and accomplished in accordance with these instructions and procedures.
3.
Corrective Ste s Which Have BBecl Taken anu Results Achieved The proposed permanent revision -to SI 4.11.A.l-e has been reviewed and determined to be correct by the fire protection engineer.
In addition, Procedure BF SDSP-2.11, Review, Approval, and Change of Sito-Generated Procedures/Instructions, was issued on February 20, 1986.
This procedure establishes the controls on changes of this type for the purpose of eliminating incorrect evaluations and procedural deficiencies.
For
- example, changes of an immediate nature to'a SI must now be additionally reviewed by PORC within 14 days of the change.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations P
The review process and controls stipulated in Procedure BF SDSP-2.11 should prevent further violations.
The permanent revision to SI 4.11.A.l-e was issued.
5.
Date Mhen Full Com liance MillBe Achieved Full compliance has been achieved.