ML18039A243

Provides Response to Violations Noted in Insp Repts 50-259/97-11,50-260/97-11 & 50-296/97-11.Corrective Actions: Step 3.24 Added to Precautions & Limitations Section Addressing Normal Position of Selector Switch

ML18039A243
Person / Time
Site:	Browns Ferry
Issue date:	01/28/1998
From:	Crane C TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-259-97-11, 50-260-97-11, 50-296-97-11, NUDOCS 9802050368
Download: ML18039A243 (18)

Text

CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RXDS)

ACCESSION NBR:9802050368 DOC.DATE: 98/01/28 NOTARIZED: NO DOCKET FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259

'0-2'60 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFXLlATXON CRANE,C.M. Tennessee Valley .Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Provides'response to violations noted in insp repts 50-259/97-11,50-260/97-11 &. 50-296/97-11.Corrective actions:

Step 3.24 added to,"Precautions E Limitations" section addressing normal position of selector switch.

.DISTRIBUTION CODE: IE01D'OPIES RECEIVED:LTR' ENCL '*, SIZE:.

TITLE: General (50 .Dkt)-Insp Rept/Notice of Violation Response NOTES:

RECIPIENT COPIES . RECIPIENT COPIES 0 ID CODE/NAME LTTR ENCL XD CODE/NAME LTTR ENCL R

PD2-3-PD 1 1 DEAGAZXO,A 1 1 INTERNAL: ACRS 2 2 AEOD/SPD/RAB 1 1 AEO C 1 1 DEDRO 1 1'.

LE CENTE 1 1 NRR/DRCH/HHFB 1 1 1 1 NRR/DRPM/PERB 1 1 NUDOCS -ABSTRACT 1 1 OE DIR .1 .1 OGC/HDS3 1 1 RGN2 FILE 01 1 1 D

E ERNAL: LITCO BRYCE,J H NRC PDR 1,1 1 1 NOAC NUDOCS FULLTEXT 1

1 1

1 0 N

I NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19

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Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 Christopher M. (Chris) Crane Vce President, Browne Ferry Nuclear Rant

-"January 28, 1998 U. S. Nuclear Regulatory Commission 10 CFR 2. 201 ATTN: Document Control Desk Washington, D.C. 20555 Gentleman:

In the Matter of Tennessee Valley Authority'ocket Nos. 50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) NRC INSPECTION REPORT 50-259 r 50-260 I 50-296/97-11 REPLY TO NOTICE OF VIOLATION (NOV) AND NOTICE OF DEVIATION This letter provides TVA's replies to the subject NOV and deviation transmitted by letter from M. S. Lesser, NRC, to O.,J. Zeringue, TVA, dated January 2, 1998. In the letter, two violations of NRC requirements and one deviation were identified.

The first violation involved the lack of procedural control of the Control Room Emergency Ventilation System selector switch. TVA admits this violation. The second violation was

,cited for failure to prepare a trend report required by procedures. TVA admits this violation. The deviation was for failure to revise certain plant procedures associated with testing of motor-operated valves. TVA admits the deviation.

98020503b8 980128 PDR ADQCK 05000259 6 PDR na((glar(guiana(asinaui

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U.S. Nuclear Regulatory Commission Page 2 January 28, 1998 t

Enclosure 1 contains TVA's reply to the NOVs. Enclosure 2 contains TVA's reply to the deviation. No commitments are made in these replies. If you have any questions, please contact me at (205) 729-3675.

'"8'in"cerely,

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~ M. Crane

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Enclosures cc (Enclosures):

Mr. A. W. De Agazio, Project Manager U..S.. ,Nuclear. Regulatory Commission One White Flint, North Rockville Pike '1555 Rockville, Maryland 20852 Mr. Mark S. Lesser, Branch Chief U.S. Nuclear Regulatory Commission Region II 61 Forsyth Street .S.W.

Suite 23T85 Atlanta, Georgia 30303 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611 Administrator 'egional U.S. Nuclear Regulatory Commission Region II 61 Forsyth Street S.W.

Suite 23T85 Atlanta, Georgia 30303

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ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1 ~,2 ~ AND 3 INSPECTION REPORT NUMBER 50 259 g 50 260 g 50 296/97 1 1 REPLY. TO NOTICE OF VIOLATION':(NOV)

RESTATEMENT OF VIOLATION A "During an NRC inspection conducted on October .26 through December 6, 1997,, two violate;ons of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A. Technical Specification"6.:8;1..1 requires that written procedures shall be establ'ished, 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 the operation of the Control Room Heating and Ventilation Systems.

Operating-Instruction O-OI-31, Control Bay and Off-Gas Treatment Building Air Conditioning System, Revision 49, provides procedural guidance for operation of the Control Bay and Off-Gas Treatment Building air conditioning systems.

Contrary to the above, written procedures were not adequately maintained in that Operating Instruction 0-OI-

.31 did not adequately address operation of the control room emergency ventilation (CREV) system priority select switch (0-XSW-31-7214). The procedure was not properly revised when the CREV system was modified in 1993. This condition existed from that time until December 5, 1997.

This is a Severity Level IV Violation (Supplement I)."

0 TVA's REPLY TO VIOLATION A Reason For Violation A.

This violation resulted from'n inadequate Operations review of a system modification for impact on Operations procedures. -. This inadequate review was performed when a new CREV system was installed.

Specifically, as part of the new CREV syst: em installation, a selector switch was installed to ensure that both CREV trains did not initiate simultaneously. The review of this modification failed to identify the impact of the switch on

-""'-='Oper'ations'-pro'cedures. Consequently, 0-OI-31 was not revised to address operation of the switch or the configuration contr'ol 'of the .switch.

2. Corrective'Ste s Taken And Resultschieved The affected procedure (0-OI-31) has been revised as follows:

(1) The SYSTEM PRIORITY SELECTOR SWITCH, O-.XSW-31-7214 position requirement was added to the'anel lineup checklist.

(2) Step 3.24 was added to the "Precautions and Limitations" section addressing the normal position of the selector switch.

(3) Section 7.13 "Shutdown of CREV Fans to Standby" steps were added to ensure the selector switch is placed back in the normal position.

Corrective Ste s That [Have Been Or] Will Be Taken To Prevent Recurrence A review was performed of a representative sampling of DCNs which were performed by the person responsible for the review of the CREV modification. The review did not identify any additional oversights. Therefore, TVA believes that this was an isolated event.

This person is no longer employed by TVA; therefore, no personnel corrective actions were taken.

To provide assurance that no similar conditions exist in other safety systems, it will be verified that switches and controls in the Unit 2 and 3 Residual Heat Removal, Core Spray, High Pressure Coolant Injection, Reactor Core

IP

j Isolation Cooling, Residual Heat .Removal 'Service Water, Standby Gas Treatment, and Emergency Diesel Generator systems are referenced'n the appropriate procedure.'ate When Full Com liance 'Wi11" Be'Achieved TVA is in full compliance.

RESTATEMENT OF VIOLATION B., a "B. 10 CFR 50, Appendix B, Criterion V, Instructions, Procdures','='an'd Dr'Swings,'equires that activities-'affecting quality'be"perfo'rmed'n accordance with documented procedures, or drawings appropriate to the 'nstructions, circumstances.

Procedure MMDP-5, "MOV Program,".Revision 1, and its predecessor, Site Standard Practice SPP-6.51, "Program 'Plan for Generic Letter 89-10, " Revision 3, specified trending r'equirements for Generic Letter 89-10 motor-operated valves.

MMPD-5 required issuance of a motor-operated valve trending report at the completion of every testing cycle (18 months or end of each refueling outage).= SSP-6.51 had required a similar report at the same periodicity.

Contrary to the above, on November 19, 1997, the trend report required by Procedure MMDP-5 and Site Standard Practice SSP-6.51 had not been prepared.

This is a Severity Level IV Violation (Supplement I)."

TVA's REPLY TO VIOLATION B Reason For Violation B It should be noted that only SSP-6.51 was violated rather than SSP-6.51 and MMDP-5 as stated in the NOV. MMDP-5 superseded SSP-6.51 on August 20, 1997. MMDP-5 also requires a trend report to be issued after each refueling outage. The Unit 2, cycle 9 outage ended on October 19, 1997 with the closure of the generator breaker. The Inspectors who were reviewing the implementation of Generic Letter 89-10, were at BFN from November 16 to 21, 1997.

TVA's expectation for issuance of a MOV report, which would include data compilation/analysis and report approvals, is approximately three months after the end of an outage. This 0'his action is being tracked by TVA's Corrective Action Program and is not considered to be a regulatory commitment.

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expectation is consistent. with the GL 89-10 trending .report..

r'ecommendation which is after an. outage but. no more than every 2 years. Therefore, at the time of the inspection',

trend report had been issued. As a result, this NOV no'OV

."reply onl'y addresses" reports which were not issued as

'" required by SSP-'6.51; The root cause for this violation.'s management failure to cl'early de'fine",responsibil'ity'f'personnel to issue the trend.x'epos. " In addition, the person responsible for this report had 'other responsibilities not associated with the MOV program. The MOV program was not the primary work

,. activity of-..the individual., Consequently, the workload was

,.nog .properly, prioritized to ensure that a trend .report was issued.

2. Corrective Ste s Taken And Results Achieved The Unit 2, Cycle 8, and Cycle 9 MOV test data were assembled and an inclusive Unit 2 MOV trend report has 'been issued. In addition, Unit 3, Cycle 7 MOV test data was assembled, and a Unit 3 MOV trend report has been issued.

3. Corrective Ste s That [Have Been Or] Will Be Taken To Prevent Recurrence Responsibility for the MOV .trend report has been reassigned

,with the issuance of MMDP-5 in August 1997. Since August 1997, the MOV Engineer has had the responsibility to ensure the MOV trend report is issued.

'The'OV Engineer's sole responsibility is maintaining the MOV program at BFN. Consequently, the Engineer is directly involved with the entire MOV valve program.

Date When Full Com liance Will Be Achieved TVA is in full compliance.

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ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1, 2, AND 3

/

INSPECTION REPORT NUMBER 50 259 ~ '0 260 ~ 50 296/97 1 1 REPLY TO, NOTICE OF DEVIATION RESTATEMENT OF DEVIATION "During an NRC,- inspection conducted on November 17 21, 1997, a deviation from a commitment described in your January 6, 1997, letter to the NRC was identified. In accordance with "General Statement of Policy and Procedure for NRC Enforcement Actions",

NUREG-1600, the deviation is listed below:

The letter stated that plant procedures would be revised by February 21,1997, to require that the applicable system, or train, for 18 motor-operated valves (per unit). be declared inoperable if the valve was taken out of its normal (i.e.,

safety) position for testing.

Contrary to the above, on November 17, 1997, the applicable instructions for certain of the valves were not revised to incorporate the requirement. For example, Surveillance Instruction (SI) 3-SI-4.5.B.1.c(II), Revision 9, did not declare Unit 3 residual heat removal Loop II inoperable when motor-operated valves 3-FCV-74-66 was cycled. Similarly, SI 2-SI-4.5.B.1.c(II), Revision 21, did not declare Unit 2 residual heat removal Loop II inoperable when motor-operated valves 2-FCV-74-66 was cycled."

TVA's REPLY TO THE DEVIATION

1. Reason For DEVIATION

'The cause of the deviation was that a Licensing Engineer failed to place the commitment into the commitment tracking program.

A contributing factor for the deviation was that the workload of the Licensing Engineer (several major submittals in process) led to a lack of attention to detail.

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2.. Corrective Ste s Taken And Results Achieved 0 The commitment missed in the January 17, 1997, letter was placed in the commitment tracking system. This miss'ed commitment has been completed. Other commitments made in that letter to the NR'C were verified complete.

Submittals sent to" the NRC since October 1, 1996, were reviewed" to verify that "all commitments were appropriately entered into BFN commitment tracking system. No additional case was identified where a commitment was not being tracked.

3. Corrective Ste s That [Have Been Or] Will Be Taken To Prevent Recurrence Site Licensing has developed and implemented a checklist that identifies a submittal's key attributes including the commitment being placed into the commitment tracking program. The checklist will be completed by the responsible Licensing Engineer for each submittal.

Si'te Licensing personnel have been instructed of the process to be used for future submittals and reminded of the self-checking principle o f work per formance.

Date When Full Com liance Will Be Achieved TVA is in full compliance.

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