ML18037A872

Responds to NRC 940404 Ltr Re Violation Noted in Insp Repts 50-259/94-06,50-260/94-06 & 50-296/94-06 on 940219-0318. Corrective Actions:When Automatic Function Did Not Actuate, SI Stopped.Repairs Made to Resolve Subj Problem

ML18037A872
Person / Time
Site:	Browns Ferry
Issue date:	05/04/1994
From:	Machon R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9405170100
Download: ML18037A872 (9)

See also: IR 05000259/1994006

Text

REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)ESSION NBR:9405170100

DOC.DATE: 94/05/04 NOTARIZED:

NO DOCKET CIL: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

MACHON,R.D.

Tennessee Valley Authority RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 940404 ltr re violation noted in insp repts 50-259/94-06,50-260/94-06

&50-296/94-06

on'40219-0318.

Corrective

actions:when

automatic function did not actuate, SI stopped.Repairs'made to resolve subj problem.DISTRIBUTION

CODE: IEOID COPIES RECEIVED:LTR

'ENCL Q SIZE: TITL'E General (50 Dkt)-Insp Rept/Notice

of Violation Response NOTES'D RECIPIENT ID CODE/NAME'PD2-4-PD WILLIAMS,J.

INTERNAL: ACRS AEOD/DS P/ROAB AEOD/TTC NRR/DORS/OEAB

t NRR/DRIL/RPEB

NRR/PMAS/ILPBl

NUDOCS-ABSTRACT

OGC/HDS3 RES/HFB EXTERNAL: EG&G/BRYCE,J.H.

NSIC COPIES LTTR ENCL 1 1 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME TRIMBLE,D AEOD/DE I B AEOD/DS P/TPAB DEDRO NRR/DRCH/HHFB

NRR/DRSS/PEPB

NRR/PMAS/ILPB2

REG~02 RGN2 FILE 01 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1.1 1'1 1 1 1 1 1 1 1 1 1 1 1 1 1 D D NOTE TO ALL"RIDS" RECIPIENTS'

D PLEASE HELP US TO REDUCE O'ASTE!CONTACT THE DOCUMENT CONTROL DESK, t ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION

LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

Te lessee Ve ep s,',~e..~<<es;Ce-e-e2 e-s'eLe~ea"a~.

2cCC R.~.(Rick)Machos v:>>=esce",:.B o.~s Fe q h,'.see.>>e".~04 1994 U.S.Nuclear Regulatory

Commission

ATTN: Document Control Desk Washington, D.C.20555 Gentleman:

10 CFR 2 Appendix C In the Matter of Tennessee Valley Authority Docket Nos.50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN)-NRC 1NSPECTION

REPORT 50 259I50 260I296/94

06 REPLY TO NOTICE OF VIOLATION (NOV)On April 4, 1994, NRC issued Inspection

Report 94-06 that identified

a violation for failure to comply with approved procedures

due to an inadequate

post modification

test for the automatic start function of the diesel driven fire pump.Enclosure 1 provides TVA's"Reply to the Notice of Violation" (10 CFR 2.201).Enclosure 2 contains the commitment

made in the reply.If you have any questions regarding this reply, please telephone Pedro Salas at (205)729-2636.Sincerely, R.D achon Site Vice President PAB 1E-BFN Enclosure cc: See page 2'P405170100

940504 PDR ADQt K 0500025'P Q PDR

U.S.Nuclear Regulatory

Commission

Page 2 NY 04'".."4 Enclosures

cc (Enclosures):

Mark S.Lesser, Section Chief U.S.Nuclear Regulatory

Commission

Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Brogans 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

ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)REPLY TO NOTICE OF VIOLATION (NOV)INSPECTION

REPORT NUMBER 50-259~260~296/94-'06

RESTATEMENT

OF VIOLATION"During the Nuclear Regulatory

Commission (NRC)inspection

conducted on February 19-March 18, 1994, a violation of NRC requirements

was identified.

In accordance

with'he"General'Statement

of Policy and Proc'edure

for NRC Enforcement

Actions," 10 CFR Part 2, Appendix C, the violation is listed below: Technical Specification 6.8.1.1 requires that the applicable

procedures

recommended

in Appendix A of Regulatory

Guide 1.33, Revision 2, February 1978 shall be established, implemented, and maintained.

Included in Appendix A are procedures

for modification

and testing activities.

Site Standard Practice 8.3, Modification

Test Program, requires that modification

testing shall be performed as appropriate

to demonstrate

conformance

with the design requirements

of the installed or modified component and also ascertain the effect on the overall system.Contrary to the above, this requirement

was not met in that the post modification

test performed on October 22, 1993, did not test the automatic start of the diesel driven fire pump following installation

of a new control panel.Due to a wiring problem, the automatic start function was inoperable

until discovered

when the fire pump failed a surveillance

test on January 25, 1994.This is a Severity Level IV Violation (Supplement

I)applicable

to all three units." TVA's Re 1 to Violation a.Reason For Violation This violation resulted from an error in judgment by the System Engineer (SE)assigned to the replacement

of the control panel for the Diesel Driven Fire Pump (DDFP).The work order f or replacing the control panel specif ied Surveillance

Instruction (SI)0-SI-4.11.B.1.f,"Simulated

Automatic and Manual Actuation of the High Pressure Fire Pump System," as the Post Maintenance

Test (PMT).It was

the SE's judgment that the section of the SI which tested the automatic start function did not need to be performed in order to demonstrate

operability

of the DDFP.The SE's decision was based on the similarities

in function between the old and new panel, the performance

of two manual starts (local and remote), and the satisfactory

performance

of other tests (i.e., lockout relay pick up coil and continuity).

Site Standard Practice-6.50,"Post-Maintenance

Testing," step 3.1.19, provides a method to change the SI requirements

approved in the work order including the deletion of a preplanned

PMT.When the SE decided to eliminate the automatic start function test of-the SI, the SE should have notified a work-order

planner so that the work order could be"changed

in accordance

with an approved procedure.

Additionally, the work order, step 1.5, notes that if any problems occur during the performance

of any SI or test in the instructions

record the problem and notify planning.The SE was made aware of SI problems and instructed

the craft workers to lift and to reland some of the terminal wiring on the panel.However, the SE did not notify the work order planner on the change of the SI requirements.

Finally, since the entire control panel for the fire pump was replaced, it was reasonable

to expect that the entire control functions for the new panel should have been tested.Thus, the SE erred in deciding that the automatic start function of the SI did not need to be performed.

TVA notes that while the automatic start function was disabled, the DDFP could have been actuated manually from the control room.Additionally, BFN has three electric fire pumps that are the primary assigned pumps to maintain fire-water

header pressure.2~Corrective

Ste s Taken and Results Achieved When the automatic start function did not-actuate, the SI was stopped.A Problem Evaluation

Report was generated to determine the root cause of the event and to develop corrective

actions.Repairs were made to resolve the automatic start problem.After the repairs were made, the SI was successfully

completed on January 28, 1994.Appropriate

personnel corrective

action was taken to address the SE's actions.3~Corrective

Ste s That have been or Sill Be Taken ToPrevent Recurrence

TVA concluded that this event was an isolated incident and occurred because of the errant decision of the SE;therefore, no additional

corrective

actions are required.

However, TVA will require SEs to review this NOV reply to heighten their awareness of potential impacts when the entire PMT is not performed on a work order or a design change notice.Date When Full Com liance Will Be Achieved Full compliance

was achieved'on January 28, 1994, upon the successful

completion

of the SI.El-3

ENCLOSURE 2 TENNESSEE VALLEY AUTHORZTY BROWNS FERRY NUCLEAR PLANT (BFN)REPLY TO NOTZCE OF VZOLATZON (NOV)ZNSPECTZON

REPORT NUMBER 50-259q260q296/94

06 COMMZTMENTS

TVA will require system engineers (SEs)to review this NOV reply to heighten their awareness of potential impacts when the entire post maintenance

test is not performed on a work order or a'esign change notice.The SE reviews will be completed by June 29, 1994.