IR 05000259/1986020
| ML18031A533 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/11/1986 |
| From: | Brady J, Cantrell F, Andrea Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18031A532 | List: |
| References | |
| 50-259-86-20-EC, 50-260-86-20, 50-296-86-20, NUDOCS 8607070217 | |
| Download: ML18031A533 (88) | |
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- ~4 UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report Nos. 50-259/86-20, 50-260/86-20, and 50-296/86-20 Licensee:
Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.
50-259, 50-260, and 50-296 License Nos.:
DPR-33, DPR-52, and DPR-68 Facility Name:
Browns Ferry 1, 2, and 3 Meeting Conducted:
May 28, 1986 project Engineers:
jg.
B. Bra A. H.
ohnson Approved By:
F.
S. Cantrell, ection Chief Division of Reactor Projects 4J~~lS'c Date Signed 4 ii Fl'.
ate Signed pt'teSigned SUMMARY An enforcement conference was held at Region II on May 28, 1986 at 9:00 a.m.
EDT to review seven (7) issues relating to a breakdown in management controls.
The seven issues were:
1.
2.
3.
~
6.
7.
Cable Tray Not Designed to Mithstand OBE Delinquent Corrective Action for Overloaded Cable Trays Failure to Take Prompt Corrective Action Concerning Diesel Generators Configuration Control Problems Failure to Evaluate a Change for Unreviewed Safety Question Incorrect Design Specifications on Design Drawings Incomplete RHR Crosstie License Amendment Submittal TVA gave a chronology for each issue and the results of their investigations.
The Browns Ferry Nuclear Plant Site Director concluded the presentation by reviewing the new programs which have been or will be initiated by the new management to correct the many TVA problems.
The Deputy Director of Nuclear Power for TVA concluded by saying that because the TVA management problems are deep rooted, it will. take more time to correct; however, the new management believes the new programs will address the fundamental cause of these problems.
Attachment 1 contains the slides used by TVA during the presentation.
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REPORT DETAILS Attendance NRC R.
D. Walker, Acting Deputy Regional Administrator 0.
R. Muller., Project Director (NRR)
R. J. Clark, Project Manager (NRR)
A. B, Beach, Deputy Director Enforcement ( IE)
V.
W. Panciera, Deputy Director, Division of Reactor Safety (DRS)
S.
P. Weise, Branch Chief, Division of Rea'ctor Projects (DRP)
G.
R. Jenkins, Director,.Enforcement and Investigation Coordination Staff (EICS)
F.
S. Cantrell, Section Chief, DRP J. J.
Blake, Section Chief, ORS G.
L. Paulk, Senior Resident Inspector, DRP C. A. Patterson, Resident Inspector,'RP C.
R. Brooks, Resident Inspector, DRP A. H. Johnson, Project Engineer, DRP J.
B. Brady, Project Engineer, DRP L. Trocine, Enforcement Specialist, EICS TVA C.
C.
R.
L.
T ~ A.
J.
P.
W.
C.
J.
G.
R.
L.
R.
Mc T.
D.
B.
C.
L. S.
J.
E.
G.
G.
J.
H.
R. 0.
J..
D.
J.
W.
F. A.
Mason, Deputy Manager of Nuclear Power Gridley, Director, Safety and Licensing Ippolito, TVA Licensing Stapleton, TVA Engineering Bibb, Site Director, Browns Ferry Nuclear Plant (BFNP)
Walker, Deputy Site Director, BFNP Lewis, Plant Manager, BFNP Keon, Unit 2 Superintendent, BFNP Cosby, Maintenance Superintendent, BFNP Morris, Compliance, BFNP Richardson, Deputy Manager Site Licensing, BFNP Huston, Deputy Director Nuclear QA,. BFNP Turner, QA Manager, BFNP Rinne, Modifications, BFNP Barnet Chief Civil Engineer, BFNP Wolcott, Nuclear Engineering, BFNP Hutton, TVA Licensing Szczepanski, TVA Nuclear Safety Staff Event Discussions The Acting Deputy Regional Administrator opened the meeting and asked for any opening remarks from TVA.
Mr. C.
C. Mason, the Deputy Manager of Nuclear Power; stated that TVA had publicly acknowledged a
management control breakdown several months ag I
He stated that Browns Ferry had been previously criticized for not bringing to the Enforcement Conferences the responsible people involved.
He said they had made every effort to do that this time.
Mr. S.
P.
Weise reviewed the NRC enforcement concerns for the seven issues related to the management control breakdown.
Mr. W.
C. Bibb gave the Site Directors overview emphasizing the installation of new corporate and site management, procedures upgrades, baseline walk-downs, maintenance improvement programs and the addressing of seismic concerns.
He pointed out that the new management controls emphasize accountability, responsibility, and performance.
Mr. D. T.
Nye addressed the cable tray over loading issue.
A CAR (81-035)
was issued in February 1981 with information being provided to the design organization in March 1981.
A OCR was issued in October of 1982 with a
corrective action completion date of January 1983.
The completion date was extended 8 times with a final date of June 1985, when the design memorandum was issued.
It stated that the cable trays were not seismically qualified.
The root cause for not taking prompt corrective action was identified as inadequate management attention.
Contributing causes were identified as organizational separation and the existance of separate corrective action programs.
The root causes for overloading of the trays were 1) lack of recognition of seismic requirements i~ the original design, 2) designers-<<
lack of familiarity with seismic requirements, and 3) inadequate configura-tion control.
Corrective actions identified were 1) seismic requirement definition, 2) better configuration control procedures, and 3) physical modification or justification for the as is condition.
Mr. J.
P.
Stapleton addressed the incorrect design specification problem.
The root cause of the problem was identified as a failure of the design control program to update five (5)
Browns Ferry elementary drawings from generic specifications to Browns Ferry specific specifications.
Corrective action included 1)
a review of elementaries, 2)
a review of the specifica-tion differences, 3) issuance of a condition adverse to quality for tracking and correcting the problem, 4) walkdown inspection for five of eighty affected panels (NMS, RPS),
and 5) issuance of an ECN to correct the drawings.
Future corrective actions include 1) review of RHR system drawings and 2) change of the control board procedure.
Mr. T.
D. Casby addressed items concerning prompt corrective action for the diesel generators.
An inadequate program for disposition of vendor recom-mendations was identified as the root cause for not fully completing a
previous NRC commitment to incorporate diesel generator vendor recommenda-tions into plant procedures.
A vendor manual program has been initiated to insure compliance with vendor manual requirements with completion scheduled prior to star tup.
Supervisory signoff and sample verification will be keys to corrective action implementation.
During installation of battery rack modifications, an incorrect stud material was installed resulting in seismic disqualification of the battery rack.
The root cause was identified as an inadequate modification installation procedure and personnel erro,
e Corrective actions include restoration of the battery rack and a critique.
Future act'ion will include gA review of jobs and procedures prior to start of work.
A non-functioning oil pressure switch on all four Unit
and
.
diesel generators was attributed to a vendor supplied equipment deficiency coupled with inadequate pre-op testing.
Inadequate surveillance procedures for control room indicators were a contributing factor to the problem.
Corrective actions include 1) restoring control room indication function-ality, 2) procedure revisions, and 3) modification of the start motor function of the switch.
Mr. T.
0.
Cosby addressed the.
4KV shutdown board normal and alternate control power source wiring reversal.
Inadequate modification installa-tion procedures and post-modification testing were identified as root causes.
A.contributing factor was non-rigid adherence to subsequent surveillance procedures.
Corrective action included correction of the wiring problem.
Management emphasis will be placed on rigid adherence to procedures, questioning and reporting of apparent discrepancies, and written verification of surveillance workability by the performer.
Mr. B.
C.
Morris addressed the issue of changing secondary containment damper timing without prior NRC approval.
Damper timing criteria was questioned by the engineering test group.
Fuel handling restrictions were imposed pending re-analysis for the fuel handling accident scenario.
Analysis was done using modern analysis methodology for 2; 5, and 10 second closure times.
Analysis confirmed reactor zone damper timing is not critical to the analysis results.
A decision was made to clarify FSAR statements for refuel/reactor zone damper timing during the annual FSAR update.
Control guide movements did occur during the period when fuel handling restrictions were imposed.
Mr. R.
McKeon addressed the, LPRM changeout procedure violation.
Root causes of the violation were 1) use of a procedure which did not minimize the potential for physical damage to the LPRM, 2)
a pre-job briefing which did not include all aspects of the operation, and 3) the occurrence of an unanticipated and unplanned configuration when the damaged LPRM caught behind the source pin rack.
Corrective action included 1) suspension of LPRM removal and replacement activity, 2) review and revision of the procedure, 3) reading of dosimeters for all personnel involved, 4) reloca-tion of the source pin rack, 5) placing the area radiation monitor on the lowest practical setting, and 6)
a critique of the incident with all per-sonnel perfarroing LPRM movement prior to resuming movement.
Mr. J.
D. Wolcott addressed the inadequate RHR system Technical Specification amendment request.
A review of the requirements for the RHR Cross-Tie was conducted (AEC-ACRS concerns
'on basement flooding).
TVA did not include the concern in the expedited Technical Specification amendment because the concern was not in the Technical Specification basis and was not clearly spelled out in the FSAR.
TVA was aware of the AEC-ACRS concern on basement flooding at the time of the submittal for amendment.
Corrective action will be a change to update the FSAR this year to document the basis for the RHR Cross-,Ti I
Mr. J.
H.
Rinne reviewed the reason for the Unit 2 torus reinspection program.
The program was developed from programmatic deficiencies identi-fied in NRC inspections and sample inspections by TYA of Unit 3 supports.
Sample TVA inspections in Unit 2 have revealed the same type deficiencies.
All torus attached piping supports, external structural features, and internal torus features are being inspected, Oeviations will be evaluated and those that are unacceptable wi 11 be repaired.
Modification instructions are being revised to give more detail on instructions for the installation and inspection of piping supports.
A training program on the installation and inspection of pipe supports has been initiated.
Third party inspections will be used as a check on inspection adequacy.
Mr. Bibb concluded the presentation by presenting a list of programs and principles that have been or will Ixe initiated by the new TVA management.
They include walkdowns, equipment labeling, procedural review and update, critiques, management attitude changes, organizational stability, technical specification review, equipment reliability (PMS),
system integrity (operational readiness review),
and the restart test program.
Mr. Walker closed the meeting thanking TVA for their presentation.
Attachment:
Enforcement Conference Agenda
I
A'7lAHM6 gJ7 ENFORCEMENT CONFERENCE AGENDA MAY28. 1988 PRESENTQR I. OPENING REMARKS II. SITE DIRECTOR'S OVERVIEW III. INSPECTION REPORT 85 41 A. CABLE TRAY SEISMICITY B. FAILURE TO TAKE CORRECTIVE ACTION IV. INSPECTION REPORT 8605. ERRONEOUS SEPARATION CRITERIA ON DRAWINGS V. INSPECTION REPORT 85 45. DIESEL GENERATOR ANNUALMAINTENANCE/
VENDOR MANUALS Vl. INSPECTION REPORT 85 45. BATTERY" RACK STUDS Vll. INSPECTION REPORT 85-57. DIESEL GENERATOR OIL PRESSURE SWITCHES VlI I. INSPECTION REPORT 85-57. SHUTDOWN BOARD WIRING ERROR IX. INSPECTION REPORT 85-57. STANDBY GAS TREATMENT X. INSPECTION REPORT 85-57. LPRM CHANGEOUT EVENT OTHER ITEMS:
I. RHR CROSS TIE TECHNICAL SPEC.
t II. UNIT 2 TORUS REINSPECTION CONCLUDING REMARKS DR. GRACE/MASON BIBB NYE NYE STAPLETON COSBY F COSBY COSBY COSBY MORRIS MCKEON WOLCOTT R INNE MASON
E
ENFORCEMENT CONFERENCE S!TE DIRECTOR'8 OVEBVlEM PROGRAMMATIC MANAGEMENTBREAKDOWN IN CONTROLS o
IDENTIFIED IN SALP REPORT AND 50.54(f) LETTER SEPTEMBER 17. 1985 o BFN PERFORMANCE PLAN ADDRESSES THESE CONCERNS o
HIGHLIGHTS OF NEW MANAGEMENTSCHEMES TO RESOLVE CONCERNS o
NEW CORPORATE AND SITE MANAGEMENT o
SITE REORGANIZATIONUNITIZINGOPERATIONS o
PROCEDURES UPGRADE o
BASELINE WALKOOWN o
SEISMIC CONCERNS BEING ADDRESSED (MAY 14 5 15 NRC MEETINGS)
o MAINTENANCEIMPROVEMENT PROGRAM NEW MANAGEMENTCONTROLS EMPHASIZE o ACCOUNTABILITY" o
RESONSIBILITY o
PERFORMANCE
DESCRIPTION OF PROBLEM FEBRUARY l981 CAR 81 Q35 ISSUED MARCH 1981 INFORMATIONPROVIDED TO DESIGN ORGANIZATION OCTOBER 1982
--OCR ISSUED JANUARY 1983 JUNE l985 CORRECTIVE ACTION COMPLETION DATE EXTENDED 8 TIMES JUNE 1985 DESIGN MEMORANDUMISSUED STATING CABLE TRAYS NOT SEISMICALLYQUALIFIED JULY l 985 NRC NOTIFIEO BY 4HOUR REPORT ANO LER
/
ROOT CAUSE OF PROBLEM INADEQUATE MANAGEMENTATTENTION TO TIMELY CORRECTIVE ACTION CONTRIBUTING CAUSES ORGANIZATIONALSEPARATION SEPARATE CORRECTIVE ACTION PROGRAMS
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CORRECTIVE ACTIONS QUARTERLY CORRECTIVE ACTION MEETINGS ESCALATION PROCESS SITE DIRECTOR FOLLOW UP COMMON CORRECTIVE ACTION SYSTEhl
ly
PROBLEM
TRAY OVERFILL o
INADEQUATE-DESIGN
IMPROPER INSTALLATION AND ADDITIONS
l
ROOT CAUSES o
LACKOF RECOGNITION OF SEISMIC REQUIREMENTS IN THE ORIGINAL DESiGN
DESIGNERS LACKOF FAMILIARITY WITH SEISMIC REQUIREMENTS o
INADEQUATECONFIGURATION CONTROL
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CORRECTIVE ACTION o
SEISMIC REQUIREMENTS DEFINED CONFIGURATION CONTROL PROCEDURES PHYSICAL MODIFICATIONS OR JUSTIFY AS IS
I T
PROBLEM
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f REFERENCED SEPABATlON CBlTERlA e
FiVE, 8 F ELEMENTARIES ISSUED 396S 730 E 915 RPS 730 E 9i 8 ENGINEERING SAFEGUARDS 730 E 92l RCIG 730 E 927 PBlMABY.CONT ISO 730 E 930 CORE SPRAY GENERIC DESIGN SPEC)FICAT).ON tpfAS BEFEREilCED ON ELEQEblTARIES ELECT EQUIPMENT SEPARATION 22A1421
BROWSES FERRY SPECIFIC DESIGN SPECIFICATiON SUBSEQUENTLY ISSUED 22A2809 (CORRECT SPEC)
o BRQWRS F RBY DRAT!)RGS NOT UPDATED
A C
)'OOT CAUSE OF PROBLEM N
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FAILURE OF DESIGN CONTROL PROGRAM
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t CORRECTIVE ACTIONS WHICH HAVE BEEN TAKEN o
BEVIEVfED ELEMENTABIES o
SPECIFICATIOA REVIEWED. DIFFERENCES IDENTIFIED 8 ANALYZED NO DESIGN IMPACT
.
o CONDITION ADVERSE TO QUALITYWRITTE.
TQ TRACK AND CORRECT PROBLEM
VfALKDQMNINSPECTION DONE ON PANELS NMS PANELS (912, 9-14)
RPS (9-'I5. 9-17)
o revs IX r ROeeSS TO CORREL DRAMtNG.
ISSUE DATE BY JUNE I
NO FIELD MODIFICATIONS REQUIRED
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FUTURE CGRRECTlVE ACTlGNS
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e BEYIENf RHR SYSTEM:
DRAVflNGS ELEMENTABIES CONTROL DRA'MfjNGS FLOW DIAGRAMS a
IF NG DISCREPANCIES ARE FOUND V/ITH RHR REVIEVf. NO FURTHER ACTIONS PLANNED IF DISCBEPANC/ES ARE FOUND, THEY V/ILL BE ANALYZEDAND PROGRAM EXPANDED o
BASELtNE PROGRAM IN PROCESS MALKDOVfNS SYSTEMS REVIEVl DESIGN CRiTERIA BEING DQCUMENTED CHANGE CQNTRQL BOARD PROCEDURE IR PROCESS PROCEDURE DUE JUNE
I
MAlNTENANCEIMPROVEMENT EXCELLENCE IS OUR GOAL MAJOR TARGETS FOR IMPROVEMENT SUPERVISORY INVOLVEMENT FAILURE EVALUATIONS ORGANIZATIONALSTRUCTURE OBJECTIVES WORK PlANNING AND CONTROL PLANNINGAND SCHEDULING TRAINING PROCEDURES PREVENTIVE 'MAINTENANCE
EVENT DESCRIPTlON TECHNICALSPECIFICATION 4.9.A.1.D REQUIRES THAT EACH DIESEL GENERATOR BE GIVEN AN ANNUALINSPECTION IN ACCORDANCE V/ITH INSTRUCTIONS BASED ON MANUFACTURER'S RECOMMENDATIONS. DIESEL GENERATOR MANUFACTURER INFORMATION INCLUDES RECOMMENDATIONS FOR MAINTENANCETO BE PERFORMED AT 3, 6, AND 12 YEAR INTERVALS; DURING STARTUP REVIEW IN AUGUST 1985, TVA DISCOVERED THAT THESE RECOMMENDED MAINTENANCEITEMS HAD NOT BEEN PERFORMED. ADDITIONALLY,FOLLOWUP INTERACTIONVlITHTHE NRC RESIDENTS PO!NTED OUT THAT A PREVIOUS NRC COMMITMENTTO
. INCORPORATE DIESEL GENERATOR VENDOR RECOMMENDATIONS INTO PLANT PROCEDURES HAD NOT BEEN FULLYCOMPLETE I I
ROOT CAUSES INADEQUATE PROGRAM FOR DISPOSITION OF VENDOR RECOMMENDATIONS CONTRIBUTING FACTORS PERSONNEL ERROR INADEQUATECOMMITMENTTRACKING CORRECTIVE ACTIONS
.::PERSONNELERROR EVALUATION MANAGEMENTATTENTION TO SATISFACTORY COMMITMENTIMPLEMENTATION SAMPLE VERIFICATION VENDOR RECOMENDATlONS FOR DIESEL GENERATORS DISPOSITIONED
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VENDOR MANUALPROGRAM CONSOLIDATEI-CATALOG INFORMATION MAINTENANCE REVIEW FOR CONTROL CRITERIA DETAILED MAlNTENANCE TECHNICAL REVIEW CRITERlA DISPOSITION APPLlCABLE RECON MENDATIONS
VENDOR MANUALSCHEDULE RESTART MILESTONE CONSOLIDATION/CATALOG)NG COMPLETE ENVIRONMENTALLYQUALIFIED EQUIPMENT TECHNICAL SPECIFICATION VENDOR REQUIREMENTS PROGRAM COMPLETION
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EVENT DESCRIPTION THE UNITS 1. 2 AND 3 DIESEL GENERATIORS
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ARE EACH PROVIDED NECESSARY DC POWER FROM A DEDICATED SEISMICALLYQUALIFIED
~ BATTERY BANK IN APRIL 1985. THE BATTERY RACKS WERE SEISMICALLYDISQUALIFIED RESULTING FROM ANALYSISOF DEFICIENCIES INITIALLYNOTED IN NRG RESIDENT INSPECTIONS DURING RACK INTEGRITY RESTORATION IN APRIL 1985, 4 OF 64 ANCHOR STUD WELDS SEPARATED FROM CONCRETE BASE PLATES.
IN SEPTEMBER 1986. THE SEISMIC INTEGRITY OF THE RACKS WAS DISQUALIFIED DUE TO TVA FINDING THE ANCHOR STUD MATERIALWAS NOT SUITABLE FOR THE APPLICATIO r
ROOT CAUSE INADEQUATE PROCEDURES FOR BATTERY MODIFICATIONS INSTALLATION PERSONNEL ERROR IN REPAIR PROCEDURE SPECIFICATION CORRECTIVE ACTIONS
~
BATTERY RACK INTEGRITY RESTORED PRESENT MODIFICATIONS PROCEDURES ADEQUATE COMMUNICATIONSICRITIQUES
EVENT DESCRIPTION A MULTIPORT OIL PRESSURE INSTRUMENT
~
MANIFOLDWAS FOUND ON ALL FOUR UNIT 1 AND 2 DIESEL GENERATORS WITH ONE SENSING PORT WHICH WAS NOT CONNECTED TO THE PRESSURE PORT RESULTING IN THE NONFUNCTIONALLYOF THE OIL PRESSURE SWITCH CONNECTED TO THIS PORT. THIS CONDITION WAS DISCOVERED BY TVA DURING A ROUTINE CALIBRATIONCHECK ON ONE OF THE DIESEL GENERATORS WHICH WAS INOPERABLE FOR MAINTENANCE.SUBSEQUENT FOLLOWUP BY TVA FOUND THE CONTROL ROOM INDICATORS OPERATED BY THESE SWITCHES NONFUNCTIONAL
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ROOT CAUSES VENDOR SUPPLIED EQUIPMENT DEFICIENCY WITH INADEQUATE PREOP TESTING CONTRIBUTING FACTORS INADEQUATESURVEILLEANCE PROCEDURES (FOR CONTROL ROOM INDICATORS)
CALIBRATION
'e CORRECTIVE ACTIONS RESTORE FUNCTIONALITY PROCEDURE REVISIONS CALIBRATIONMETHOD ADEQUATE MODIFICATION
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EVENT DESCRIPTION THE 4KV SHUTDOWN BOARD A IS PROVIDED NORMAL 250 VDC CONTROL POWER FROM A
.
DEDICATED BATTERY AND ALTERNATE CONTROL POWER FROM A MAIN UNIT BATTERY DURING PREPARATION FOR THE PERFORMANCE OF TECHNICAL SPECIFICATION BATTERY DISCHARGE TESTING. TVA FOUND THAT THE NORMALAND ALTERNATE CONTROL POW'ER SOURCE WIRING WAS REVERSE J
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ROOT CAUSES INSUFFICIENT PROCEDURES FOR MODIFICATIONINSTALIATION AND INADEQUATE POSTMODIFICATION TESTING CONTRIBUTING FACTORS NONRIGID ADHERENCE TO PROEDURES DURING SUBSEQUENT SURVEILLANCE CORRECTIVE ACTIONS-WIRING CORRECTED PRESENT MODIFICATONS PROCEDURES ADEQUATE MANAGMENTEMPHASIS RIGID ADHERENCE TO PROCEDURES QUESTION AND REPORT APPARENT DISCREPANCIES SURVEILLANCE PEFORMER ATTEST TO VfORKABILITYOF INSTRUCTIONS UNAUTHORIZEDAIDS (NAMEPLATES)
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~I INSPECTION REPORT 8557 ITEM 5A VIOLATIONOF 10 CFR 60 59 AND TECHNICAL SPECIFICATION 5 4.8 FOR CHANGlNG SECONDARY CONTAINMENTDAMPER TIMING VIITHOUTPRIOR NRC APPROVAL
I I
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DAMPER TIMING CRITERIA DAMPER TIMINGCRITERIA QUESTIONED BY ENGINEERING TEST GROUP REANALYSIS PERFORMED FOR FUEL HANDLINGACCIDENT TO RESQLVE TIMINGCONCERN FUEL HANDLINGRESTRICTIONS IMPOSED PENDING COMPLETION OF REANALYSIS
FSAR SECTION 5 3 4.2 THE TOTALTIME REQUIRED TO SWITCH FROM NORMAL CONTAINMENTVENTILATIONSYSTEM TO THE STANDBY GAS TREATMENT SYSTEM UPON DETECTION OF HIGH RADIATION IS RELATIVELYSMALL. THE RADIATIONMONITOR RESPONSE TIME IS I SECOND. AND THE REACTOR ZONE ISOLATION DAMPERS (PNEUMATIC DRIVE) ARE CLOSED IN 2 SECONDS UPON RECE!PT OF SIGNALS FROM THE MONITOR. STARTUP OF THE STANDBY GAS TREATMENT SYSTEM, BLOWER MOTORS IS WITHIN 5 SECONDS FROM TIME OF THE SIGNAL THE PROPER DAMPERS (ELECTRICMOTORDRIVEN) IN THE SBTS TRAINS ARE FULLY OPENED IN 30 SECONDS.
THE 1SECOND RESPONSE t
ON THE RADIATIONDETECTION PLUS THE 2SECOND RESPONSE ON THE ISOLATION OAMPER. IS LESS THAN THE TRANSPORT TIME FROM THE SURFACE OF THE FUEL POOL TO THE ISOLATION DAMPER. AND THEREBY ASSURES THAT THE RELEASE FROM A FUEL HANDLINGACCIDENT WILLBE CONTAINED BY THE SECONDARY CONTA'INMENT. ALLSTANDBY GAS TREATMENT TRAINS WILLBE PRODUCING FULL FLOW WITHIN30 SECONDS OF A SECONDARY ISOLATION SIGNAL.
COMMENTS REFUEL ACCIDENT EVENT OF INTEREST REFUEL ZONE EXHAUST DAMPERS CLEARLYASSUMED TO CLOSE IN 2 SECONDS REMAINING DAMPERS NOT EXCLUDED FROM 2 SECOND CRITERIA
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ANALYSIS RESULTS USED MODERN ANALYSIS METHODOLOGY ANALYZEDUSING 2510 SECOND CLOSURE TIMES ANALYSISCONFIRMED REACTOR ZONE DAMPER TIMING NOT CRITICAL TO RESULTS EVEN WITH IO SECONDS CLOSURE TIME.-
CONSIDERABLE MARGIN EXISTED TO BTP 800 CRITERIA DECISION MADE TO CLARIFY FSAR STATEMENTS DURING ANNUALFSAR UPDATE TO CLARIFY REFULE/REACTOR ZONE. fSAR DESCRIPTION ACCURATE fOR EXHAUST DAMPERS
l
LPRM CHANGE OUT VIO ATION FAILURE TO HAVE ADEQUATE (259/260/296/85-57-06)
PROCEDURE PER 10'CFR 50 CRITERION V EVENT DISCRIPTION DURING LPRM MANIPULATIONIN UNIT 2 FUEL POOL THE SET POINT (100MR/HR) FOR AREA RADIATION MONITOR (ARM) 2RM90141 WAS EXCEEDED. THIS RESULTED IN SECONBARY CONTAINMENTISOLATION STANDBY GAS TREATMENT INITIATION AND RADIATIONMONITOR 2RM90141 ALARM.EVENT REPORTED TO NRC UNDER 10 CFR 50.72 1. LPRM CHANGE OUT PERFORMED IN ACCORDANCE VllITH PROCEDURE IMI92.2 2. 0800 NOVEMBER 20. 1985 PREJOB BRIEFINGS HELD.
3. 0900 NOVEMBER 20. 1985 LPRM MANIPULATORS IN FUEL CAUSED ENGINEERED SAFEGUARDS FEATURES (ESF)
TO ACTIVATE
EVENT DISCRIPTION CONT.
4. NOVEMBER 20.1985 LPRM CHANGE OUT STOPPED LICENSEE 5. 1330 NOVEMBER 20. 1985 =CRITIQUE HELD ON EVENT ROOT CAUSE l. THE USE OF A PROCEDURE WHICH OlD NOT MINIMIZETHE POTENTIAL FOR PHYSICAL DAMAGETO THE LPRM.
2. A PREJOB BRIEFING WHICH OIO NOT INCI UOE ALL ASPECTS OF THE OPERATION.
3. AN UNANTICIPATEDAND UNPLANNED CONFIGURATION WITH THE DAMAGED LPRM CAUGHT BEHIND THE SOURCE PIN RACK.
CORRECTIVE ACTIONS TAKEN I. THE LPRM REMOVALAND REPLACEMENT ACTIVITYWAS SUSPENDED UNTILA FULL.lNVESTIBATIONOF THE INCIDENTWAS COMPLETED AND EVALUATED
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CORRECTIVE ACTIONS TAKEN CONT
2. THE LPRM PROCEDURE WAS REVIEWED BY ALL RSPONSIBLE SECTIONS AND REVISED TO INCORPORATE THE FOLLOWING CHANGES:
(A) ADDITIONALR)DIOLOBICALCAUTION STATEMENTS ADDED.
(8) A STATEMENT ADDED TO REQUIRE A FORMAL OPERATIONAL BRIEFING PRIOR TO THE START OF WORK (C) THE METHOD OF PHYSICALLYMOVING THE LPRM WAS REVISIED TO MINIMIZETHE POTENTIAL FOR SIMILAR EVENTS 3. THE THERMOLUMINESCIENTDOSIMETERS (TLD) ON ALL PERSONELL INVOLVEDIN THIS INGIDENTWERE PROCESSED 4. LUDLUM300 ARM SETTINGS HAVE BEEN PLACED AT-THE
. LOWEST PRACTICAL SETTING.
5. THE SOURCE PIN RACK WAS RELOCATED 6. THE INCIDENT WAS REVIEWED WITH ALL PERSONNEL PERFORMING LPRM MOVEMENT PRIOR TO LPRM MOVEMENT RESUMIN l
AMENDMENTREQUEST SEQUENCE OF EVENTS.
2/20/85 NEEDED TO MODIFY UNIT 2 RHR PIPE SUPPORTS WITH UNIT 3 IN OPERATION o
MEETING KITH NRC AND REGION tl ON SEISMIC REQUIREMENTS FOR XTIE FEATURE
."o ELECTED TO DELETE XTIE TECH SPECS 2/22/&5 AMENDMENTPORC REVIEWED PLANT MANAGER APPROVED 2/25/85 AMENDMENTREQUEST SENT TO NRC 3/1/85 AMENDMENTTO NSRB FOR REVIEW 3I9I86 UNIT 3 SHUTDOWN 5/31/85 NSRB APPROVED AMENDMENT I
l'/22/85 REQUEST FGR ADDITIONALINFORMATION FROM NRC 1/13/86 AMENDMENTREQUEST M/ITHDRAWN
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SYSTEM DESIGN BASIS FOR RHR XTIE
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PROVIDE COBE COOLING AND DECAY HEAT REMOVALVflTHTOTAL LOSS OF RHR AND CORE SPRAY o
OPERATE WITH AFFECTED UNIT'S BASEMENT FLOODED
~ a PROVIDE 5000 GPM THROUGH 2 HEAT EXCHANGERS o
NOT REDUNDANT
REGULATORY BASIS FOR RHR XTIE o AECACRS CONCERNS ON BASEMENT FLOODING o TVA AGREED TO INSTALL RHR XTIE o
BASIS FOR TECHNICAL SPECIFICATION REQUIREMENTS UNKNOWN o
NOT INCLUDED IN RHR SAFETY DESIGN BASIS
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BROWNS FERRY DESIGN BASIS ACCIDENTS o CONTROL ROD DROP o
LOCA o
REFUELING ACCIDENT o
MAIN STEAM LINE BREAK OTHER POSTULATED EVENTS IN FSAR o.ATMS o
INTERNAL FLOOD -;;
o OTHERS
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CORRECTIVE ACTION FSAR CHANGE WILL BE INCLUDED IN THIS YEARS ADMENDMENT
SUMMARY RHR XTIE IS NOT UTILIZED IN DESIGN BASIS ACCIDENT ANALYSES
'ls XTIE IS NOT PART OF THE SAFETY DESIGN BASIS FOR THE RHR SYSTEM XTIE IS FOR BEYOND DESIGN BASIS EVENTS SIMILAR FEATURES (WATER TIGHT DOORS IN RHR PUMP ROOMS) ARE NOT TYPICALLYIN BVfR TECH SPECS AMENDMENTREQUEST CONTAINED ABOVE INFORMATION
e Iy
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USQ DETERMINATION NRC QUESTIONED WHETHER NEW ANALYSIS CONSTITUTED USQ ENGINEERING STAFF PERFORMED USQD NRC SUBSEQUENTLY CONCURRED WITH DETERMlNATIQN
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QUESTION:
TORUS SUPPORTS WHY ARE WE REVIEWING SUPPORTS AFTER HAVING INSTALLEDTHEM IN THE LAST OUTAGE BACKGROUND:
NRC INSPECTION REPORT 852602 (OATEO MAY.14.1985)
5 OF 7 PIPE SUPPORTS INSPECTED EXHIBITED DEVIATIONS FROM THE DOCUMENTED REQUIREMENTS.
SAMPLE INSPECTIONS BY TVA OF ADDITIONALU3 SUPPORTS REVEALED PROGRAMATIC DEFICIENCIES IN PIPE SUP PORT INSTALLATION.
ANSWER:
FUTHER SAMPLE INSPECTIONS BY TVA IN U2 OF PIPE SUPPORT INSTALLATONSALSO..
REVEALED THE SAME TYPE PROGRAMATIC DEFICIENCIES.
OPERATIONAL READINESS INITIATEDSAMPLE INSPECTONS OF EXTERNALAND INTERNAL TORUS STRUCTURAL FEATURES DETERMINED THAT THE SAME TYPE DEFICIENCIES EXISTED.
BASED ON SAMPLE INSPECTION RESULTS.
DECIDED TO INSPECT ALLTORUS ATIACHED PIPING SUPPORTS. EXTERNAL STRUCTURAL FEATURES, AND INTERNALTORUS FEATURES DEVIATONS FROM DESIGN DOCUMENTS OR PROCE DURES ARE BEING EVALUATEDBY ENGINEERING. THOSE FOUND TO BE UNACCEPTABLE ARE BEING REPAIRE C,s
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CORRECTIVE ACTION MODlFICATIONADDITIONINSTRUCTION 23. SUPPORT OF PIPING SYSTEMS IN CATEGORY I STRUCTURES. HAS BEEN REVISIED TO GIVE MORE DETAILED INSTRUCTIONS FOR THE INSTALLATIONAND INSPECTION OF PIPING SUPPORT.
SPECIAL MECHANICALMAINTENANCEINSTRUCTION (SMMT)
14.4.1.3 L HAS BEEN WRITTEN AND IS BEING USED OR WILL8E USED TO REINSPECT PIPING SUPPORTS IN ALL THREE UNITS.
INSPECTION TEAMS USING SMMT 14.4.1.3 L ARE MADE UP OF AN OE ENGINEER. A QC INSPECTOR. AND A MODIFICATIONSSTEAMFITTERfOREMAN.,
A FORMAL TRAINING PROGRAM WILLBE INITIATEDTO TRAIN ALLPERSONNEL ASSOCIATED WITH THE INSTALLATIONAND INSPECTION OF PIPE SUPPORTS.
THIS TRAININGWILLPRIMARILYBE BASED ON LESSONS LEARNED FROM THE SMMI INSPECTION RESULTS.
FUTURE PIPING SUPPORT INSTALLATIONWILLBE MONITORED TO ENSURE THAT THE INSTALLATIONIS IN ACCORDANCE WITH ALL DRAWINGS AND SPECIFICATION REQUIREMENT
LONG TERM CORRECTIVE ACTIONS CRITIQUE SYSTEM DEVELOPED LESSON LEARNED STOP JOB PROCEDURES UPGRADE PROGRAM
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