ML18037B001

Responds to NRC 940701 Ltr Re Violation Noted in Insp Rept 50-259/94-14.Corrective Actions:Form SSP-26, Voluntary Entry Into TS LCO for Plant Mods Prepared to Obtain Necessary Evaluations & Approvals for Entering LCO 3.5.C.4

ML18037B001
Person / Time
Site:	Browns Ferry
Issue date:	07/28/1994
From:	Machon R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9408010261
Download: ML18037B001 (11)

Text

P RIDRIT Y I (ACCELERATED RIDS PROCESSING)

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:9408010261 DOC.DATE: 94/07/28 NOTARIZED:

NO CIL:50-259 Browns Ferry Nuclear-Power Station, Unit 1, Tennessee UTH.N~~ME AUTHOR AFFILIATION CEiIN, R.L).Tennessee Valley Authority REC I P.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 940701 ltr re violation noted in Insp Rept 50-259/94-14.Corrective actions:Form SSP-26,"Voluntary Entry Into TS LCO for Plant Mods" prepared to obtain necessary evaluations

&approvasl for entering LCO 3.5.C.4.DISTRIBUTION CODE: IEOID COPIES RECEIVED:LTR t ENCL L SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: DOCKET 05000259 RECIPIENT ID CODE/NAME PD2-4-PD INTERNAL: ACRS AEOD/DSP/ROAB AEOD/TTC NRR/DORS/OEAB NRR/PMAS/IRCB-E DIR t EG~X7~M 0 2 RGN2 FILE 01 EXTERNAL: EG&G/BRYCE,J.H.

NSIC COPIES LTTR ENCL 1 1 2 2 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/DEIB AEOD/DSP/TPAB DEDRO NRR/DRCH/HHFB NUDOCS-ABSTRACT OGC/HDS3 , RES/HFB NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE iVASTE!CONTACTTHE DOCUMENT CONTROL DESK, ROO!1I PI-37 (E>i T.504-083)TO LLIhf!NATE YOUR MARIE FROM DISTRIBUTION LISTS I OR DOCUMENTS YOU DON"I'L'ED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL 21

Tennessee vasey Authority, post otiice Box 2000.Decatur, Alabama 35609-2000 R.D.(Rick)Machon Vice President, Brovrns Ferry Nuclear Plan;July 28, 1994 U.S.Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.20555 Gentlemen:

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 INSPECTION REPORT 50-259'0-260I 50-296/94-14 REPLY TO NOTICE OF VIOLATION (NOV)This letter provides our reply to the subject NOV regarding inadequate oversight of the recovery activities associated with Browns Ferry Unit 3.The NOV was transmitted by letter from Thomas A.Peebles, NRC, to O.D.Kingsley Jr., TVA, dated July 1, 1994.While TVA does not contest the underlying issue described in the NOV and Inspection Report, TVA does not believe that a violation of a legally binding requirement was involved.Instead, the issue appears to involve noncompliance with a commitment made in a NRC/TVA meeting on May 10, 1994.Therefore, TVA respectfully requests that NRC reclassify this NOV as a Notice of Deviation.

On May 10, 1994, TVA presented plans for controlling Unit 3 recovery activities that'equire entry into a Unit 2 Limiting Conditions for Operation (LCOs).The controls were based on NRC Inspection Manual Part 9900,"Maintenance

-Voluntary Entry Into Limiting Conditions for Operation Action Statements to Perform Preventive Maintenance." The Inspection Manual was used since it was the best source of guidance for similar situations.

9408010261 940728 PDR ADOCK 05000259 8 PDR

U.S.Nuclear Regulatory Commission Page 2 July 28, 1994 During the meeting, TVA indicated that formal, documented evaluations and management reviews of the Unit 2 LCOs entered for performing Unit 3 recovery activities would be performed due to the special circumstances involved.The reviews and evaluations were beyond those normally conducted'by on-shift licensed personnel when entering LCOs.TVA implemented the controls for these reviews and evaluations using plant procedures before commencing the initial Unit 3 activity that placed Unit 2 into an LCO.TVA believes that the NOV concerns a situation involving noncompliance with the commitment to perform the additional reviews and evaluations for each of the Unit 2 LCOs involved with an Emergency Diesel Generator (EDG)outage before entering that LCO for the Unit 3 recovery work.Accordingly, TVA requests that the NRC reclassify the NOV as a Notice o Deviation.

The enclosure provides TVA's reply to the NOV.There are no commitments contained in this submittal.

Zf you have any questions regarding this reply, please contact Mr.Pedro Salas at{205)729-2636.R.D.M on Site Vice President Enclosure cc: See page 3 U.S.Nuclear Regulatory Commission Page 3 July 28, 1994 Enclosure cc (Enclosure):

Mr.Mark S.Lesser, Section Chief U.S.Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637'thens, 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 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)REPLY TO NOTICE OF VIOLATION (NOV)INSPECTION REPORT NUMBER 50-259~50-260 g 50-296/94/14 RESTATEMENT OF THE VIOLATION During an NRC inspection conducted during the period of June 13-17, 1994, a violation of NRC requirements was identified.

In accordance with the"General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR part 2, Appendix Cg the violation is listed below: 10 CFR 50, Appendix B, Criterion V, states that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.Contrary to the above, Browns Ferry procedure SSP-7.1,"Work Contxol," which was controlling an activity affecting quality, was inadequate in that it did not include a review by personnel cognizant of current plant conditions.

Consequently, on June 13, 1994, the work planning process to conduct the Unit 3 design modification W17275A did not require entry into a Unit 2 Limited Condition of Operation (LCO).Entry into Unit 2 LCO 3.5.C.4 for the Residual Heat Removal Service Water System (RHRSW)was not included in the planning process as required and it was not properly entered until after the work had commenced.

This is a Severity Level IV violation (Supplement I.D).

TVA's Re 1 to the Violation NOTE TVA does not contest the underlying issue described in the above NOV.However, TVA is providing the following discussion to clarify the information in the NOV and associated Inspection Report about Unit 2 Technical Specification (TS)LCO 3.5.C.4 not being properly entered until after the work had commenced.

The involved on-shift Shift Technical Advisor (STA)was aware that removing the 3D Emergency Diesel Generator from service resulted in LCO 3.5.C.4 being entered.However, the STA did not consider it necessary to stop work, immediately log the LCO entry, and have additional reviews and evaluations performed expressly for LCO 3.5.C.4.The basis for this action was that the 30-day duration for LCO 3.5.C.4 is the same or longer than the other involved LCOs, extensive management reviews had been performed for entering the other LCOs to perform the work, and the duration of the work scope was significantly less than 30 days.Subsequently, the STA decided to log entry into the LCO.The STA amended the LCO Tracking Log to show entry into the LCO at 0100 Central Standard Time (CST).Also, the STA made the appropriate"late entry" at 0600 CST in the STA log.The STA's actions were consistent with TVA procedural controls.Reason for The Violation This issue resulted from inadequate procedural guidance for voluntarily entering Unit 2 LCOs in support of Unit 3 recovery activities.

Specifically, Site Standard Practice (SSP)-7.1,"Work Control," did not require: Utilization of an on-shift licensed individual during the planning process to ensure that the latest plant information was used, Utilization of the most current LCO status when planning voluntary LCO entries for Unit 3 recovery activities, and Performance of a"last minute" review by cognizant on-shift personnel to ensure that plant conditions were consistent with those originally planned and that entry into unplanned LCO's was not required.E-2

.2.Corrective 8te s Taken and Results Achieved A Form SSP-26,"Voluntary Entry Into a TS LCO for Plant Modifications," was prepared to obtain the necessary evaluations and approvals for entering LCO 3.5.C.4.3~TVA generated a Problem Evaluation Report (PER)to determine the root cause and to develop corrective actions.Based on the results of TVA's evaluation, TVA revised SSP-7.1 to require that:~The on-shift STA be involved in the planning process so that LCO evaluations are performed using the latest plant information,~The current LCO tracking information be used in the planning process, and~The STA conduct a"last minute" review of the existing LCO/Inoperable equipment log to ensure that emergent plant conditions will not require entry into LCOs not previously approved.Corrective Ste s That have been or Vill Be Taken to Prevent Recurrence The corrective actions described above are considered adequate for preventing recurrence of this situation.

The above actions will ensure that the appropriate management review is obtained for each LCO before entering a Unit 2 LCO for Unit 3 recovery work.4.Date Vhen Full Com liance Vill he Achieved Full compliance was achieved on June 17, 1994, when the SSP-7.1 was revised and issued with the actions specified in Section 2 above.E-3