ML18033A750

Responds to NRC 890407 Ltr Re Violations Noted in Insp Repts 50-259/89-08,50-260/89-08 & 50-296/89-08.Corrective Actions: Safety Instruction for intermediate-range Monitor Will Undergo Validation Process to Ensure Accuracy

ML18033A750
Person / Time
Site:	Browns Ferry
Issue date:	05/12/1989
From:	Michael Ray TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8905190512
Download: ML18033A750 (12)

Text

AC GEE PATED DI FTKBt '730K DEMON iTRAT10N SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

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"ESSION NBR: 8905190512,

~ DOC. DATE: 89/05/12 NOTARIZED: NO DOCKET CIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee

~ 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH. NAME AUTHOR AFFILIATION RAY,M.J. Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 890407 50-259/89-08,50-260/89-08 ltr &

re violations noted in Insp Repts 50-296/89-08.

DISTRIBUTION CODE: IEOID TITLE: General (50 COPIES RECEIVED:LTR ( ENCL Dkt)-Insp Rept/Notice of Violation Response 3 SIZE: 7 NOTES:1 Copy each to: B.Wilson,D.M.Crutchfield,B.D.Liaw,S.Black 05000259 g

R.Pierson, 1 Copy each to: S.Black,D.M.Crutchfield,B.D.Liaw, 05000260 ~

R.Pierson,B.Wilson 1 Copy each to: S. Black,D.M.Crutchfield,B.D.Liaw, 05000296 R.Pierson,B.Wilson D

RECIPIENT RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL 8 PD 1 1 GEARS,G 1 1 I TERNAL: ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1 AEOD/TPAD 1 1 DEDRO 1 1 NRR SHANKMAN,S 1 1 NRR/DEST DIR 1 1 NRR/DLPQ/PQEB 1 1 1'

NOTES'OPIES NRR/DOEA DIR 11 NRR/DREP/RPB 10 NRR/PMAS/ILRB12 0 WIE N,J 1

2 1

1 1

2 1

1 NRR/DREP/EPB 10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT OGC/HDS2 1

1 1

1 1

1 G LE 02 1 1 RGN2 FILE 01 1 1 NRC PDR 1 1 R EXTERNAL: LPDR 1 1 NSIC 1 1 I

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NOTE 'IO ALL "RIDS" RECIPIENIS:

PLEASE HELP US 'IO RENKZ WASTE! CDNZACI'IHE DOCUNEti7 CONIROL DME, ROOD Pl-37 (EXI', 20079) TO EZJMMATE YOUR NAME- FRY DISXRXKTZEGN LISTS EQR DOCUMEÃIS YOU DON'T NEED)

"'OTAL NUMBER OF COPIES REQUIRED: LTTR 30 ENCL 30

TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 5N 157B Lookout Place MAY 1~ 1%9 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) UNITS 1, 2, AND 3 NRC INSPECTION REPORT NOS. 50-259/89-08, 50-260/89-08, AND 50-296/89-08 RESPONSE TO NOTICE OF VIOLATIONS

. This letter is to provide TVA's response to your letter from Linda J. Watson to Oliver D. Kingsley, Jr. dated April 7, 1989, wh.ich 'transmitted the subject inspection report. This report cited TVA with -two violations. An extension of the response due date to May 22, 1989 was agreed to in a conversation with B. Little on May 4, 1989.

Enclosure 1 provides background information and TVA's response to the violations cit'ed in the subject report.

A list of commitments is provided in enclosure 2.

If you have any questions, please telephone Patrick P. Carier,, BFN, at (205) 729-3570.

Very truly yours, TENNESSEE VALLEY AUTHORITY Manag r, Nuclear Licensing and Regulatory Affairs Enclosures cc: See page 2 85'0;i5'0 12 =5'0512 PL1R 1-'lDVCI: 1.15000" ':-9 ya'I CQ PDC An Equal Oppor tunity Employ'er

U.S. Nuclear Regulatory Commission

~ MAY 18 1988 cc (Enclosures):

Ms. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson,=Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000

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ENCLOSURE 1 e NRC

RESPONSE

INSPECTION REPORT NOS. 50-259/89-08, 50-260/89-08, AND 50-296/89-08 LETTER FROM L. i1. HATSON TO O. D. KINGSLEY, JR.

DATED APRIL 7, 1989 Violation 260/89-08-01 Technical Specification (TS) Section 6.8.1.1.C, Procedures, requires that written procedures shall-be established, implemented and maintained covering the surveillance and test activities for safety-related equipment.

Contrary to the above, on February 3, 1989, steps 7.14.6.1 and 7.14.6.2 of 2-SI-4.2.C-3.2, "Functional Test of Unit 2 Intermediate Range Monitor (IRM) Rod Blocks/Scrams," were not followed resulting in the failure to remove jumpers that had been installed earlier during the performance of the surveillance instruction. These jumpers disabled the source range monitor (SRM) scram function which was not required for the plant conditions at that time.

This is a Severity Level IV Violation and is applicable to Unit 2.

TVA Res onse 1.~

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Admission or Denial of the Alle ed Violation TVA admits the violation occurred as stated.

2. Reasons for the Violation The jumpers were not removed because of personnel error. The instrument maintenance technicians ( IM techs) did not correctly perform step'7.14.6 of the IRM rod block/scram functional test. This step states, "If jumpers were installed in (previous) steps 7.5.6.2 and 7.5.6.3 . . . PERFORM steps 7.14.6.1 and 7.14.6.2. Otherwise OMIT (N/A) . . . and CONTINUE . . ." Steps 7.14.6.1 and 7.14.6.2 remove the jumpers..

The placement and removal of the jumpers were added to the procedure by a recent procedure change. The IM techs were using this revision for the first time. In. the IM techs'revious experience with this procedure, these jumpers had not been installed. Therefore, they assumed the jumpers were not installed, rather than referring to the referenced steps in the procedure.

U.S. Nuclear Regulatory Commission 0 An additional contributing factor was that the performance of the surveillance instruction (SI) spanned two shifts and involved two different crews. The day shift placed the jumpers and turned the SI over to the evening shift to complete. However; the shift turnover did not cover installation of the jumpers. The evening shift did not remove the jumpers in step 7.14.6 of the SI.

3. Corrective Ste s Which Have Been Taken and Results Achieved Current maintenance craft have reviewed a description of this finding and received instructions on performance and necessity of proper turnover procedure.

4. Corrective Ste Which Will Be Taken to Avoid Further Violations

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The SI for the IRM rod block/scram functional test will undergo a validation process to ensure its accuracy and workability. Any necessary corrections or improvements to the SI will be implemented following the validation.

The need for adequate turnover and review of previously performed steps in procedures following a turnover will be incorporated into continuing craft training programs.

5. Date When Full Com liance Hill Be Achieved Validation of SI 2-SI-4.2.C-3.2 will be performed by June 1, 1989.

Current maintenance craft will be trained in the necessity for adequate turnovers and to review previously performed steps following a turnover by July 31, 1989.

Violation 259 260/89-08-02 TS 4.9.A.2.a. requires a weekly surveillance of the 250 volt DC power system batteries conditions.

Contrary to the above, the weekly surveillance due on February 15, 1989 for the shutdown boards C and D batteries, was not performed until February 21, 1989.

This is a Severity'evel IV Violation and is applicable to Units 1 and 2.

0 U.S. Nuclear Regulatory Commission TVA Res onse

1. Admission or Denial of the Alle ed Violation TVA admits the violation occurred as stated.

2. Reasons for the Violation The weekly surveillance was missed because of inadequate control and tracking of surveillances and personnel error by the maintenance general foreman.

The scheduling program was set up to project due dates and did not perform a positive verification. of completed surveillances.

The electrical maintenance general foreman responsible for performance of the surveillance was not the normal foreman or the normal alternate. This acting general foreman checked out the scheduled work package 'containing the SI on February 14, 1989, the day it, was scheduled to be "performed. The SI had an incorrect due date which had already passed. The general foreman contacted the scheduling section and verified that the surveillance had been performed on the date listed and that none were overdue. The scheduling contact stated, however, that all the weekly survei llances were due and should be performed. The general foreman did not realize the shutdown board batteries'I was included in the set of weekly surveillances required and assumed the SI included in the work package was issued in error. Therefore, he did not assign any craft personnel to perform the surveillance. The following day, the general foreman did not ensure that all scheduled work had a completed data package.

3. Corrective Ste s Nhich Have 8een Taken Personnel corrective actions have been taken with the general foreman involved.

The shutdown board battery surveillance was successfully performed on the C and D batteries on February 21, 1989.

The surveillance scheduling and tracking program has been evaluated as part of a task force reviewing the entire surveillance program.

U.S. Nuclear Regulatory Commission The Plant Manager issued a memorandum which incorporated an SI task force recommendation in the area of surveillance scheduling and tracking requiring the work control unit to ensure positive verification that an SI has been completed on th'e due date.

Additionally, the memorandum required the notification of the Plant Manager if an SI cannot be verified complete on the due date.

The maintenance foremen have reviewed a description of this finding.

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4. Corrective Ste s Hhich Hill Be Taken to Avoid Further Violations No further corrective action steps will be required to prevent recurrence of this violation.

5. Date Hhen Full Com liance Hill Be Achieved The, corrective action steps which have been taken are adequate to prevent recurrence; therefore, full compliance has been achieved.

ENCLOSURE 2 LIST OF COMMITMENTS 1., The surveillance instruction (SI) for intermediate range mon'itoring (IRH) rod block/scram functional (2-SI-4.2.C-3.2) test will undergo a validation process to ensure accuracy and workability of the procedure by June 1, 1989.

2. Any necessary corrections or improvements to the SI for IRH rod block/scram functional test will be implemented following the validation.

. Current maintenance craft wi 1 1 be trained in the necessity for adequate. turnovers and to review previously performed steps in procedures following a turnover by July 31, 1989.

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