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)

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.