ML18037A506
| ML18037A506 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/06/1993 |
| From: | Salas P TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9310130140 | |
| Download: ML18037A506 (8) | |
Text
ACCELERATED DOCUMENT DISTR1BUT1ON S YSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9310130140 DOC.DATE: 93/10/06 NOTARIZED: NO DOCKET ¹ FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 e
50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 p 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION I
SALAS,P.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
D
SUBJECT:
Suppls response to notice of violation from Insp Repts 50-259/93-25,50-260/93-25,
& 50-296/93-25,in response to NRC 930907 RAI.Commitments for RPS
& PCIS encl.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation R sponse NOTES:
RECIPIENT ID CODE/NAME PD2-4-PD WILLIAMS,J.
COPIES LTTR ENCL 1
1 1
1 RECIPIENT ID CODE/NAME ROSS,T.
COPIES LTTR ENCL 1
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D INTERNAL: ACRS AEOD/DSP/ROAB AEOD/TTC NRR/DORS/OEAB NRR/DRIL/RPEB NRR/PMAS/ILPBl NUDOCS-ABSTRACT OGC/HDS3 RES/HFB EXTERNAL: EG&G/BRYCEgJ.H.
NSIC 2
2 1
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1 1
1 1
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1 1
1 1
1 1
1 1
1 AEOD/DEIB AEOD/DSP/TPAB DEDRO NRR/DRCH/HHFB NRR/DRSS/PEPB NRR/PMAS/ILPB2 OE~LE 02 GN2 FILE 01 NRC PDR 1
1 1
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1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! COYTACT THE DOCUMENT COYTROL DESK, I'COOhl Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAhIE FROM DISTI<IBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
D TOTAL NUMBER OF COPIES REQUIRED:
LTTR 25 ENCL 25
0
Tennessee Valley Autnorrty. Post Ofhce Box 2000. Decatur, Alabama 35609 October 6, 1993 U.
S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Gentleman:
In the Matter of Tennessee Valley Authority Docket Nos.
50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN)
NRC INSPECTION REPORT 50-259'0-260~
296/93 SUPPLEMENT REPLY TO NOTICE OF VIOLATION (NOV)
NRC letter dated September 7,
- 1993, from R. V. Crlenjak (NRC) to Dr. Mark 0. Medford (TVA), requested additional information concerning TVA's response to the subject violation.
Specifically, TVA was requested to:
- 1) indicate why the additional actions identified in TVA's internal investigation of the event were not discussed in the response to the NRC; 2) justify why these corrective actions were not, considered necessary to fully address the violation; and, 3) why the corrective actions should not be completed in a more timely manner.
With regard to Item 1, the assessment conducted of the incident investigation (II) results identified the development of a standard methodology to insert trips in the Reactor Protection System (RPS) as an enhancement and not a necessary action to preclude recurrence of the event.
It was felt that due to the unique configuration of the turbine stop valve and the main steam isolation valve (MSIV) the actions
- taken, as described in TVA's response, would be effective in preventing recurrence.
In TVA's judgement, the existing practice of relying on the shift personnel's ability to evaluate drawings to detect what actions were necessary to comply with technical specification action statements was adequate.
- However, TVA considered that this practice alone placed an unnecessary burden on the crew that could be alleviated by the development of a standard methodology.
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'9310130140 931006 PDR ADOCK 05000259 Q
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U.S. Nuclear Regulatory Commission Page 2
October 6,
1993 In response to Item 2, TVA offers no justification for omitting the corrective action from the original response.
In retrospect, TVA considers that, due to both the significance of the planned actions and the impact that the change in operating philosophy will have, the actions should have-been discussed in the response.
In response to Item 3, the due date for the completion of the development of the standard methodology was established based upon the scope of the undertaking and the need for training prior to implementation.
In addition, the actual scope of the development of the methodology is greater than implied in your letter.
The approach currently being taken is not only to address the RPS but also to include the Primary Containment Isolation System (PCIS).
The completion dates for the development of this methodology is predicated on three reasons.
First, the approach of providing procedural guidance for inserting trips deviated considerable from the current practice of relying on the knowledge of the operators and their ability to research drawings/prints in an expeditious manner.
Due to the potential significance of errors that could occur in the implementation of this new methodology, TVA considered that a gradual implementation of the program coupled with specific training was appropriate.
- Second, as noted in our response to Item 1, TVA believes that the existing practice of relying on the ability of operators to review drawings is an adequate method to determine necessary actions to comply with TS actions statements.
- Third, TVA has heightened operators'wareness of the unique configuration of the turbine stop valves and MSIVs through required reading, training, and revising the affected divisional functional surveillance instructions.
TVA is currently ahead of the schedule for completion of the development of the standard methodology for the RPS and the PCIS.
The development of the methodology for taking compensatory measures in the event of implementation of TS action statements, as well as the necessary training, will be completed by December 15, 1993, for the
- RPS, and May 1,
- 1993, for the PCIS.
- Finally, NRC also expressed a concern that the NOV response did not address the failure mode of the turbine stop valve limit switch.
TVA did not include this information in the response because it considered that it had already met its reporting obligations for this type of hardware malfunction.
In LER 260/93008, which had been submitted in July 15,
- 1993, TVA had reported that "the limit switch for the g1 turbine stop valve was disassembled.
A piece of the switch lever
U.S. Nuclear Regulatory Commission Page 3
October 6,
1993 return spring was found lodged in the switch that prevented internal movement of the switch."
Since the failure of the limit switch had not caused the operators to make the mistake and the information had been previously reported, TVA did not consider it pertinent to address in the NOV response.
The enclosure to this letter describes the commitments in this reply.
If you have any questions regarding this reply, please telephone me at (205) 729-2636.
Sincerel Pedro Salas Manager of Site Licensing Enclosure cc (Enclosure):
Mr. R. V. Crlenjak, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637
- Athens, Alabama 35611 Mr. J.
F. Williams, Project Manager U. S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. D.
C. Trimble, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852
S
ENCLOSURE Tennessee Valley Authority Browns Ferry Nuclear Plant (BFN)
Reply to Letter for Additional Information Inspection Report Number 50-259 260 296 93-25 COMMITMENTS 1.
The development of the methodology for taking compensatory measures in the event of implementation of TS action statements, as well as the completion of the necessary training, will be completed by December 15, 1993, for the RPS.
2.
The development of the methodology for taking compensatory measures in the event of implementation of TS action statments, as well as the necessary training, will be completed by May 1, 1993, for the PCXS.
S-I