ML18038B808
| ML18038B808 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/17/1997 |
| From: | Machon R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9701240148 | |
| Download: ML18038B808 (14) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM'RIDS)
ACQES5ION 'NBR:9701240148 DOC.DATE: 97/01/17 NOTARIZED: NO DOCKET,O FACIL: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 MACHONiR.D.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk),
SUBJECT:
Responds to NRC 961220 ltr re violations noted in insp repts 50-259/96-12,50-260/96-12
!l 50-296/96-12.Corrective actions:
Operating instructions 0-OI-30F a GOI-300-1 will be revised.
.DISTRIBUTION CODE: IE01D COPIES,RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/No'tice.of Violation Response NOTES:
INTERNAL:
RECIPIENT ID CODE/NAME PD2-3-PD ACRS NRR/DRCH/HHFB NRR/DRPM/PERB'E DIR RGN2.
FILE 01 COPIES.
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RECIPIENT ID CODE/NAME WILLIAMS,J.
AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS3 COPIES LTTR ENCL 1
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1 EXTERNAL: LITCO BRYCEiJ H
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1 NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US'O REDUCE WASTE!
CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SD-5(EXT. 415-2083)
TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER'F COPIES REQUIRED:
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e Tennessee Vajey Authonty. Post Office Box 20CC. Deca:u. Aabarna 35609.2CCO January 17, 1997 R. D. (Rlck)'Machon Vice President. Browns Ferry Nucfear Rant U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 10 CFR 2.201 Gentleman:
In the Hatter of Tennessee Valley Authority Docket Nos.
50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN)
NRC INSPECTION REPORT 50 259 r 50 260 / 50 296/96 12 REPLY TO NOTICE OF VIOLATION (NOV)
This letter provides our reply to the subject NOV transmitted by letter from Mark S. Lesser, NRC, to O.
D. Kingsley Jr.,
TVA, dated December 20, 1996.
The NOV involved one violation with two examples for failure to establish and implement written procedures.
TVA admits the violation.
The enclosure contains our reply to the NOV. There are no commitments made in this reply. If you have any questions, please contact me at (205)729-3675.
Sincerely, R.
D.
M on Site Vice President Enclosure cc:
See page 2
970i240148 970ii7 PDR ADOCK 05000259 8
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U.S. Nuclear Regulatory Commission Page 2
January 17, 1997 Enclosure cc (Enclosure):
.Regional Administrator U.S. Nuclear Regulatory Commission
,Region II 101 Marietta Street, NW, Suite 2900
- Atlanta, Georgia 30323 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 Rockville, Maryland 20852
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ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1 ~
2 ~
AND 3 INSPECTION REPORT NUMBER 50-259, 50-260, 50-296/96-12 REPLY TO NOTICE OF VIOLATION (NOV)
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"Technical Specification 6.8.1.1.a requires that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Paragraph 4
of Appendix A of Regulatory Guide 1.33 recommends procedures for operation of safety-related BWR systems.
Procedure O-OI-30F, Common and DG Building Ventilation, Revision 15, provides pre-startup/standby readiness requirements and procedural steps for operation of the diesel generator and intake building ventilation.
Section 4.1.2.4 requires that the system lineup checklists are current using Attachment 2A, Common Building Ventilation Panel Lineup Checklist, Unit 3.
Attachment 2A states that the required position of the diesel auxiliary board room 3EA and 3EB exhaust fan handswitches 3-HS-030-0243 and 3-HS-030-244 is ON.
Note (1) to this requirement states that unless maintenance is being performed, these fans should be kept in service to prevent excessive temperatures when the diesel generator 480V auxiliary boards are energized.
Procedure O-GOI-300-1, Attachment 15.18, dated November 15,
- 1996, provides Operations with routine checklists for position of Unit 3 Control Bay heating and ventilation handswitches and equipment position.
Corrective actions, in part, for LER 260/89022, R1 were to prepare appropriate plant instructions addressing the operation of the exhaust fans for the diesel generator auxiliary board room by February 2,
1990.
Contrary to the above, Procedure 0-OI-30F was not followed, in that on November 19,
- 1996, the diesel generator auxiliary board room 3EA and 3EB exhaust fan handswiches 3-HS-030-0243 and 3-HS-Ua0-0244 were found by the inspectors to be in the OFF position, the fans were not running, and no maintenance was being performed.
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inadequate in that it did not require verification of proper operation of the diesel auxiliary board room 3EA and 3EB exhaust fans.
This is a Severity Level IV violation (Supplement I)."
TVAv RE PL T
THE VI LA F
T Ex This example resulted from inadequate procedural guidance for the operation of the Diesel Generator Auxiliary Board Room 3EA and 3EB exhaust fans.
Specifically, Note 1 of Attachment 2A in BFN Operating Instruction (OI) 'O-OI-30F, "Common and Diesel Generator Building Ventilation Operating Instruction," states:
unless maintenance is being performed on the exhaust fans for rooms containing Diesel Auxiliary Boards 3EA and 3EB, these fans should be kept in service to prevent excessive temperatures when the Diesel Generator 480V Auxiliary Boards are energized.
Site Standard Practice (SSP)-2.2 "Writing Procedures,"
denotes the word "should" as a recommendation.
The word shall is used to denote a requirement.
Because the word should is considered a recommendation, the operator has the latitude to manipulate the ventilation in the area based on the board room area temperatures.
Utilization of shall in Note 1 would have given the proper emphasis to the information provided by the note.
2.
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TknAnR1Ahiv The appropriate operations personnel were briefed on the issue.
A caution order was placed on the hand switch for each of the Units 1, 2 and 3 Diesel Generator Auxiliary Board room exhaust fans with a statement not to remove the fans from service unless directed by the Shift Manager or the Unit Supervisor.
Engineering evaluated the design requirements for the exhaust fans in 3EA and 3EB Diesel Generator Auxiliary Board rooms.
The evaluation concluded that in cold weather conditions, operation of the fans is not critical because the low temperature of the concrete walls provide sufficient thermal storage
- capacity, and a rapid increase in the room temperature due to a change in plant operating conditions E-2
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would not be expected.
Therefore, during cold weather, manual operation of the fans is consistent with the design of the ventilation system.
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Th H
r W'o prevent recurrence of this event, Operating Instructions 0-OI-30F and 0-GOI-300-1 will be revised to provide clear directions, as to when the fans can be turned off for reasons other than a maintenance activity.
Operations management will review this event with the appropriate personnel during the next requalification training cycle'.
DWhnFll li n Wi 1 8 A hi v TVA is in full compliance.
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TVA believes this example resulted from an error during the implementation of a commitment established in Licensee Event Report (LER) 260/89022 Rl.
Specifically, in the
- LER, TVA committed to revise the appropriate instructions addressing the operation of the exhaust fans for the Emergency Diesel Generator Auxiliary Board Rooms.
In doing so, TVA revised Operations Instruction (OI) O-OI-30F, "Common and Diesel Generator Building Ventilation Operating Instruction."
The revision states:
"unless maintenance is being performed on the exhaust fans for rooms containing Diesel Auxiliary Electrical Boards 3EA and 3EB, these fans should be kept in service to prevent excessive temperatures when the Diesel Generator Auxiliary Electrical Boards are energized."
- However, the requirement to verify the Emergency Diesel Generator Auxiliary Board Room fans were in service was not appropriately depicted in General Operating Instruction (GOI) O-GOI-300-1, "Operations Routine Sheets."
The portion of the GOI applicable to the Units 1 and 2 EDG'uxiliary Board Room fans was updated to verify hand switch position.
- However, the portion of the GOI applicable to the Unit 3 EDG
'The corrective actions are considered enhancements and not commitments.
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Auxiliary Board Room fans was inadvertently not updated.
A revision to 0-GOI-300-1 was made in December 1989.
.With the.exception of the portion of the round sheets applicable to Unit 3, the required procedure changes needed to fulfi'll the commitments made in the LER were implemented as required.
Therefore, TVA considers this example isolated.
2.
TVA revised 0-GOI-300-1 to include verification of the Unit 3 Diesel Generator Auxiliary Board Room exhaust fan switch position.
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No further corrective actions are required.
4.
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Wil'1 B A hi v TVA is in full.compliance.
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