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)

See also: IR 05000259/1994014

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