ML20203J397
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA, TENNESSEE 37401 40 October 21, 1974 gig g g PARTNEASHip Mr. Norman C. Moseley, Director Directorate of Regulatory Operations j
U.S. Atomic Energy Comission Region II - Suite 818 230 Peachtree Street, NW.
J Atlanta, Georgia 30303
Dear Mr. Moseley:
This is in response to Directorate of Regulatory Operations letter RO:II:WSL 50-259/74-6, dated September 28, 1974, concerning certain activities at Browns Ferry Nuclear Plant unit 1 which appeared to be in violation of AEC regulations.
The specific citation (Section 1.B) involved modifications to the HPCI isolation instrument channels and our response is enclosed.
Section 1.A was discussed in my October 8, 1974, letter to D. F. Knuth, Director, Directorate of Regulatory Operations.
Sections 1.C. 1.D, and 1.E involved violations of technical specifications and were reported as Abnormal Occurrences, BFA0-7440W, BFAO-7443W, and BFAO-7438W.
We have reviewed RO Inspection Report No. 50-259/74-6 and find no proprietary information in this report.
Very truly yours, m
J. E. Gilleland j
Assistant to the Manager of Power Enclosure l
i 8604300179 860317 PDR FOIA MORROW 8S-782 PDR 6"
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. _DEAiT, JRCfJFGtCHB,10/ o/74 RESPONSE TO ACC-DRO IETIER
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Reference:
RO:II:WSL 50-259/74 6)
This report responds to the following alleged violation listed in Inspection Report No. 50-259/74-6.
Violation 74-61.B - Contrary to the requirements of Technical Specification 6.3.A.5, the corrective maintenance on the HFCI isolation instrr.ent channels was not reviewed, approved, and documented as required by TVA procedure SPM BFA-28.
(Details II, paragraph 2)
Response
Modification to the HPCI isolation instrument channels was performed on unit 2 under Mcxiification Change Request No. 395 and on unit 1 under Modification Change Request No. 345, both of which were orally approved by the TVA Divisien of Engineering Design before perforrance of the work. This approval was given following determinaticn that an unreviewed safety question would not be created by the modification. General Electric concurrence was expressed in their letter of transmittal for the initiating Field Deviation Disposition Request, FDDR-ER1-360, which was the substance of the modification transmitted to TVA Design by the plant's ICR 345. The modification was reviewed by the Plant Operations Review Committee as reflected by the minutes cf meeting No. 281 dated June 4,1974, on the basis of having Design oral approval and with the understanding that Design had determined no unreviewed safety question would be created by the modif.ication. The committee's recommendation for approval of the modification indiented their conclusion that an unreviewed safety question would not be created by the modification. Due to a heavy workload in TVA Design, formal transmittal of written approval and the written safety evaluation had not yet been transmitted to the plant at the time of inspection. Both have now been received.
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_ Response (continued) e In regard to supervisors' initials being omitted from the MCR, General Electric-initiated FDDR's enter the review chain at a point past where the supervisors nortally initial change requests;and their initials on such documents transmitted to TVA Design for approval are not mandatory at that stage. Their review of the document before work performance as members of the Plant Operations Review Committee is sufficient to meet the requirements of Standard Practice BFA28.
Standard Practice BFA28 has been revised to clearly-indicate the review steps intended and contains check-off sheets to ensure that all procedural requirements are met. This provides full compliance and should avoid violation in the future.
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