ML18038B631
| ML18038B631 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/26/1996 |
| From: | Machon R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9603040208 | |
| Download: ML18038B631 (14) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) f ACCESSION NBR:9603040208 DOC.DATE: 96/02/26 NOTARIZED: NO
~FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee AUTH.NAME AUTHOR AFFILIATION MACHON,R.D.
Tennessee Valley Authority RECIP.NAME RECIPIENT 'AFFIZ IATION Document Control Branch (Document Control Desk)
SUBJECT:
Provides response to NRC 960129 ltr re violations noted in insp rept 50-259/95-64,50-260/95-64
& 50-296/95-64.
Corrective actions:SOS notified of isolated valve declared affected part of fire protection sys inoperable.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
DOCKET' 05000259.
05000260 05000296 RECIPIENT ID CODE/NAME PD2-3-PD INTERNAL: ACRS AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS3 EXTERNAL LITCO BRYCEiJ H
NRC PDR COPIES LTTR ENCL 1
1 2
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RECIPIENT ID CODE/NAME WILLIAMS,J.
AEOD/DEIB AEOD/TTC EZ>HE &ENTER IR7DXc~HHHFB NRR/DRPM/PERB
OE DIR RGN2 FILE 01 NOAC COPIES LTTR ENCL 1
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D NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTEl CONTACT THE DOCUMENT'ONTROL DESK, ROOM OWFN SD-5(EXT. 415-2083)
TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDl TOTAL NUMBER OF COPIES REQUIRED:
LTTR 20 ENCL '0
4y,
Tennessee Vatey Autrerrty, Post Otfce Box 2000. Decatur. Alabama 35609.2000 R. D. (Rick) Machon Vice President, Brows Perry f4uctear Plant February 26, 1996 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
10'FR 2
Appendix C
In the Matter of Tennessee Valley.Authority Docket Nos.
50-259 50-260 50-296 BROWNS FERRY 'NUCLEAR PLANT'BFN) - NRC INSPECTION REPORT'0-,259~
50-260~
50-296/95-64 REPLY TO NOTICE OF VIOLATION (NOV)
This letter provides our reply to the subject NOV,transmitted by letter from Mark S. Lesser, NRC, to Oliver D. Kingsley, TVA, dated January 29, 1996.
This NOV involved a violation with two examples for failure to comply with BFN's Fire Protection Program.
TVA admits the violation.
The enclosure provides our response to the NOV.
No commitments are made in this letter. If you-have any questions regarding, thi;s reply, please contact Pedro Salas at (205) 729-2636.
Sincerely,,
R.
D.
chon Enclosure cc:
See page 2
Qgnqp 9603040208 960226 PDR ADQCK 05000259 8
/p
'V
U.S. Nuclear Regulatory Commission Page 2
February 26, 1996 Enclosures cc (Enclosures)':
Mr. Mark S. Lesser, Branch Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road
- Athens, Alabama 35611 Mr. J.
F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockyille, Maryland 20852
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ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNZTS I.g 2g AND 3 INSPECTION REPORT NUMBER 50-259~
50-260~
50-296/95-64
'REPLY TO NOTICE OF VIOLATION (NOV)
RESTATEMENT OF THE'IOLATION "During an NRC inspection conducted on November 19 to December 30,
- 1995, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
NUREG 1600, the violation is listed below:
Browns Ferry Unit 3 Facility Operating License Condition 2.C.(7) states that Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Final Safety Analysis Report for BFN as approved in the SEs dated December 8,
- 1988, March 6,
- 1991, March 31,
- 1993, November 2, 1995 and Supplement dated November 3, 1989.
The Final Safety Analysis Report references the Fire Protection Report as detailing the Fire Protection Program.
Section 9.3.11.C of the Fire Protection Plan, contained in the Fire Protection Report, requires that a continuous fire watch be established within one hour if preaction system 3-26-77 is inoperable.
Section III, Required Safe Shutdown Equipment, of the Appendix R Safe Shutdown Program contained in the Fire Protection Report, requires that if Unit Battery Charger 3
is unable to perform its function, then a fire watch must be established if the equipment is-not restored in seven days or equivalent shutdown capability is provided.
Contrary to the above, provisions of the Fire Protect'ion Program were not implemented in that; 1.
Preaction system 3-26-77 was inoperable from some time prior to 3:26 p.m.,
on November 22, 1995, until 12:30 p.m.,
on November 23, 1995, without a continuous fire watch being established.
2.
Battery Charger 3 could not perform its Appendix R shutdown function as of at least October 25,
- 1995, and remained in that condition for a period of over 7 days without a fire watch or equivalent shutdown capability being provided.
This is a Severity Level IV violation (Supplement 1)."
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TVA~8 REPLY TO THE VIOLATION EXAMPLE 1 Reason For The Violation This violation resulted from personnel error.
Specifically, a Modification Work Control (MWC) evaluator did. not identify that the magnetic bypass valve was within a clearance boundary on an Appendix R clearance request.
This oversight occurred because the MWC evaluator used connection diagrams and not schematic diagrams to establish the clearance boundary.
Additionally, the MWC evaluator did not include schematic diagrams in the clearance request for use by the clearance request writer/reviewer.
Contributing to the event was inadequate reviews of the clearance boundary by Operations personnel, the complexity of the clearance
- request, and their confidence in the MWC evaluator.
The Operations personnel who wrote/reviewed the clearance request relied on the MWC evaluator's expertise rather than reviewing the schematic diagrams to assess the full impact of the clearance request.
In doing so, the valve was isolated, and compensatory measures were not established for the isolated valve.
2.
Corrective Actions Taken And Results Achieved The Shift Operations Supervisor (SOS) was notified of the isolated valve and declared the affected part of the fire protection system inoperable.
As a result of this event, the SOS also evaluated existing fire protection compensatory measures and determined that previously established compensatory measures were adequate.
No personnel corrective actions were taken against the MWC evaluator since the individual was a contractor and is no longer working at BFN.
However, appropriate personnel corrective actions were taken for the clearance writer's and reviewer's actions.
TVA reinforced to the clearance writer and reviewer the need to thoroughly research, any clearance request.
Additionally, this event was discussed with Operations personnel, stressing the need to have a questioning attitude when writing or reviewing clearance requests.
TVA plans to revise the current electronic clearance request process to ensure the required reference drawings are properly listed.
Additionally, this electronic process will minimize face-to-face Appendix R clearance presentations and, therefore, will insure that the clearance request preparer and reviewer will not be influenced or guided through Appendix R clearance request by an MWC evaluator.
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Corrective Ste s That Have Been Or Will Be Taken To Avoid Further Violations 4 ~
None.
Date When Full Com liance Will Be Achieved TVA is in full compliance.
TVAiS REPLY TO THE VIOLATZON EXAMPLE 2 Reason For This Violation This violation resulted from a vendor wiring error in the local control panel for Battery charger 3.
This panel was installed during'he original design of the plant.
At that time, the bypass switch position was defeated since there was no load shedding logic requirement.
However, the vendor drawings showed that the jumper was installed.
Two factors contributed to this event.
- First, when a Design Change Notice (DCN) to install a load shedding logic circuit for the 480VAC auxiliary power system was implemented, no changes were made to the local'anel bypass switch position.
Consequently, the local bypass switch position was not required to be tested and the vendor wiring error was not discovered.
- Secondly, following implementation of the
- DCN, the Fire Protection Report (FPR) was not updated to clearly identify that the load shedding local bypass switch was a
condition for Battery Charger 3 to be available.
On October 25, 1995, during the load shedding acceptance test, it was discovered that the local panel bypass switch position did not energize battery charger 3 after a load shedding signal was received.
A work request (WR) was written to report that the local bypass switch was not functional.
During the review of the WR, a Shift Support Supervisor (SSS) was misled as to the plant conditions that would cause battery charger-3 to be considered not available.
Notwithstanding, at that time, the SSS made the correct determination that an Appendix R LCO did not have to be entered since Unit 3 was in a cold shutdown condition.'he NOV states that compensatory measures were required on or before October 25, 1995.
Although at that time the battery charger 3 bypass switch was not functional in the bypass position, this condition did not require a
bypass for load shedding because Unit 3 was in a cold shutdown condition.
On November 19, 1995, the Unit 3 mode switch was placed in the startup mode.
At that time, the need to enter an Appendix R LCO was required, and a fire watch should have been established within seven (7) days.
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'Corrective Actions Taken And Results Achieved TVA believes that this wiring error is an isolated event in that.not many panels were installed with defeated circuitry and never tested during their initial installation.
If, such events
- occur, these discrepancies are normally identified during return-to-service and other surveillance testing (this event was discovered during a load acceptance testing).
A potental drawing deviation (PDD)
(95-621) was initiated.
The PDD confirmed that the plant configuration and the drawing did not agree.
On December 8,
1995, the selector switch was repaired.
After the selector switch was
- repaired, the field configuration agreed with the drawing.
As enhancements, Site Engineering will review this event with the electrical design staff to heighten their awareness to this type of situation.
Additionally, TVA plans to revise the FPR to assure that the affected Appendix R calculation/equipment list depicts the switch.
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Site Engineering performed an engineering evaluation for the capability of battery charger 3.
The results of the evaluation determined that battery 3 was capable of supplying the required loads for a period of four (4) hours without needing a recharge.
This condition would have allowed Unit 2 and 3 to be placed in a cold shutdown condition without providing charging to battery 3.
Corrective Ste s That Have Been Or Will Be Taken To Avoid Further Violations In September 1986, during the Unit 2 recovery effort, a
wiring verification requirement for new vendor wired electrical equipment was incorporated in a site modification and addition instruction.
Consequently, this instruction requirement is sufficient to prevent future installation of new equipment with incorrect wiring.
Therefore, no further corrective actions are required.
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Date When Full Com liance Will Be Achieved TVA is 'in full compliance.
These enhancements are not considered commitments and will be tracked to completion by TVA' corrective action program (BFPER951845).
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