IR 05000259/1989053
| ML18033B356 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/01/1990 |
| From: | Wilson B Office of Nuclear Reactor Regulation |
| To: | Kingsley O Tennessee Valley Authority |
| References | |
| NUDOCS 9006120105 | |
| Download: ML18033B356 (10) | |
Text
Mr. Oliver D. Kingsley, Jr.
Senior Vice President, Nuclear Power Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801
Dear Mr. Kingsley:
SUBJECT:
REPORT NOS. 50-259/89-53, 50-260/89-53, AND 50-296/89-53 Thank your for your response of March 5, 1990, to our Notice of Violation issued on January 18, 1990, concerning activities conducted at your Browns Ferry facility.
We have examined your response and found that it meets the requirements of 10 CFR 2.201.
In your response, you denied Violation B and you admitted Violation A but did not consider Violation A a similar violation.
After careful consideration of the bases for your denial of Violation B, we have concluded, for the reasons presented in the Enclosure 2 to this letter, that a violation occurred as stated in the original violation.
Therefore, in accordance with 10 CFR 2.201(a),
please submit to this office within 30 days of the date of this letter a written statement describing steps which have been taken to correct Violation B and the results achieved, corrective steps which will be taken to avoid further violations, and the date when full compliance will be achieved.
TYA's response to Violation A disagrees that this violation was similar to the violation identified in Inspection Report 50-260/89-35.
Both violations involved your response to abnormal plant conditions, and your response to IR 89-35 identified a corrective action of counseling the operators to properly resolve abnormal conditions in order to prev'ent recurrence.
Counsel to properly resolve abnormal conditions should include the admonition to follow alarm response procedures, and this action could have been reasonably expected to have prevented the recent violation.
Therefore, we will continue to identify Violation A
as a similar violation, meeting the definition in
CFR 2, Appendix C.
The responses directed by this letter and its enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub.
L. No.96-511.
Mr. Oliver D. Kingsley, Jr.
We appreciate your cooperation in this matter.
Sincerely, (Original signed by A. Ignatonis)
Bruce Wilson, Assistant Director for Inspection Programs TVA Projects Division Office of Nuclear Reactor Regulation Enclosure:
Evaluations and Conclusions cc w/encl:
(See page 3)
'/
JUN 01 1590 Mr. Oliver D. Kingsley, Jr.
cc w/encl:
M. Runyon, Chairman Tennessee Valley Authority ET 12A 7A 400 West Summit Hill Drive Knoxville, TN 37902 C.
H. Dean, Jr., Director Tennessee Valley Authority ET 12A 11A 400 West Summit Hill Drive Knoxville, TN 37902 J.
B. Waters, Director
. Tennessee Valley Authority ET 12A 9A 400,West Summit Hill Drive Knoxvi 1 le, TN 37902 W.
F. Willis Chief Operating Officer ET 12B 16B 400 West Summit Hill Drive Knoxville, TN 37902 D. Nunn, Vice President Nuclear Engineering Tennessee Valley Authority 400 West Summit Hill Drive WT 12A 12A Knoxville, TN 37902 Dr.
M. 0. Medford Vice President and Nuclear Technical Director Tennessee Valley Authority 6N 38A Lookout Place Chattanooga, TN 37402-2801 Chairman, Limestone County Commission P. 0.
Box 188 Athens, AL 35611
.
Dr. Henry Myers, Science Advisor Committee on Interior and Insular Affairs U. S.
House of Representatives Washington, D. C.
20515 0. J. Zeringue, Site Director Browns Ferry Nuclear Plant Tennessee Valley Authority P. 0.
Box 2000 Decatur, AL 35602 E.
G. Wallace, Manager Nuclear Licensing and Regulatory Affairs Tennessee Valley Authority 5N 157B Lookout Place Chattanooga, TN 37402-2801 P. Carier, Site Licensing Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P. 0.
Box 2000 Decatur, AL 35602 L.
W. Myers, Plant Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P. 0.
Box 2000 Decatur, AL 35602 TVA Representative Rockville Office 11921 Rockvil le Pike Suite 402 Rockville, MD 20852 General Counsel Tennessee Valley Authority 400 West Summit Hill Drive ET 11B 33H Knoxville, TN 37902 Claude Earl Fox, M.D.
State Health Officer State Department of Public Health State Office Building Montgomery, AL 36130 State of Alabama bcc w/encl:
(See page 3)
Mr. Oliver D. Kingsley, Jr.
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bcc w/encl:
S.
D. Ebneter, RII D.
M. Crutchfield, NRR B.
D. Liaw, NRR S.
C. Black, NRR R.
C. Pierson, NRR G.
E. Gears, NRR D. Moran, NRR W. S. Little, NRR/RII J. Rutberg, OGC M. S. Callahan, GPA/CA R.
H. Bernhard, NRR/RII NRC Document Control Desk NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 12, Box 637 Athens, AL 35611 RI I/NRR RBernhard:vyg 5/( /90 RII/WRR WLittle 5/) /90
ENCLOSURE
EVALUATIONS AND CONCLUSIONS On January 18, 1990, a Notice of Violation was issued for a violation identified during a routine NRC inspection.
Browns Ferry responded to the Notice on March 5,
1990.
The licensee's response included a denial of Violation B which involved inadequate corrective action and contained two examples.
The NRC's evaluations and conclusions regarding the licensee's arguments are as follows:
Restatement of Violation B
CFR 50, Appendix B, Criterion XVI requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
The licensee's Nuclear Quality Assurance Manual (NQAM), Part I, Section 2.16, Corrective Action, requires that test deficiencies which, by evaluation, indicate that the item does not comply with the license design basis or will" affect plant technical specifications shall be placed on a
CAQR if
"accept-as-is" or "repair" actions are being considered.
Site Directors Standard Practice 3. 13, Corrective Action, implements the NQAM requirements.
Contrary to the above, the following two examples of test deficiencies which involved "repair" and
"accept-as-is" activities were not addressed as conditions adverse to quality.
1)
During. performance of Restart Test Procedure 2-BFN-RTP-031A, Control Bay Heating Ventilation and Air Conditioning, the Unit
and Unit 2 Control Bay chill water flows failed to meet the acceptance criteria.
The deficiencies were documented by Test Exception TE-07.
The TE was closed with a repair activity, through temporary modification TACF 0-88-002-031, without initiation of a Condition Adverse to Quality Report (CAQR).
2)
During performance of post modification test PMT-161, after installation of new shutdown board room emergency cooling units for shutdown board rooms C
8 D, the cooling units tripped prior to obtaining the required test data for the cooling capacity calculations.
Because of this, the acceptance criteria could not be verified.
Test exception EN-8 was written and dispositioned as acceptable without meeting the acceptance criteria because the test would require additional heat load to be added in the room.
Although, previous testing of the old cooling units had been conducted.using Technical Instruction TI-81, Shutdown Board Room Emergency Cooling System Performance Check, this test exception was dispositioned without issuance of a CAQR for an "accept as is" condition.
Enclosure
The shutdown electrical boards are required to be operable by the plant Technical Specifications 3.9.A since they provide electrical power to equipment used to mitigate accidents.
Surrmar of Licensee's Res onse The licensee argues that the "accept-as-is" and "repair" activities do not apply to the examples cited in the violation respectively.
The licensee notes that the Noti'ce of Violation cited Site Directors Standard Procedure (SDSP)
3. 13 as a
basis for the proposed violation (see restatement of violation of SDSP 3. 13)
but contends that additional language in this procedure allows the activities described in the violation to occur without the use of a CARR.
The licensee stated in the reply that normal preventative or corrective maintenance, rework operational wear, minor damage, and expected end-of-life cycle failures of items are not considered CAgRs.
TE-07 documented low flows for the Units
and 2 control bay chilled water pumps.
Therefore, maintenance requests (MRs) were generated.
This activity was clearly a rework activity because the maintenance requests were written to rework the pump (e.g.,
replace the impeller - not to restore the pump impeller and then reinstall it in the pump) therefore, no "repair" actions were taken.
The licensee also stated in the reply that TVA does not consider the resolution of test exception in EN-8 as an
"accept-as-is" situation under its CARR procedure.
This is based on the fact that in August 1987 Ellis and Watts conducted a performance test that exceeded the test requirement of the PMT-161, Shutdown Board Room HVAC System.
TE EN-8 was written against post-modification test PMT-161, Shutdown Board Room HVAC System, step sequences 5.8.2, 5.8.4, and 5.9.2, 5.9.4, because there was insufficient heat load available to make the unit shutdown board room air conditioning units operate in a continuous cooling mode.
They would run briefly then shutdown; consequently, no useful performance test data could be obtained.
EN-8 was submitted to NE for evaluation and disposition.
NE determined that post-modification testing on the A/C units'ooling capacity was unnecessary since a performance test on the A/C units conducted by Ellis and Watts met or excee'ded the test requirement of the PMT.
NE issued a final approval memorandum for PMT-161 test results and indicated that EN-8 was acceptable.
NRC Evaluation The NRC staff has.carefully reviewed TVA's response and considered additional information obtained onsite in March 1990.
We continue to believe a
CARR should have been written and that a violation occurred.
Exam 1 e B 1)
Based on your response and the additional information obtained, our understanding of what occurred is as follows:
During performance of 2-BFN-RTP-031A the chilled water flows were
Enclosure
about
percent less than the design flow specified in the acceptance criteria.
TE-07 was written to document the low flow rates.
To resolve the issue TVA decided to replace the pump impeller with a new one meeting the original specifications, and to hydrolase the system.
This was a "rework" activity in which the system was to be made to conform to prior specified requirements.
Following this rework the system was retested and the chilled water flows were still 10 to
percent less than specified by the acceptance criteria.
This second failure to meet test flow acceptance criteria was documented as a
new test exception, TE-10, and TE-07 was closed.
TE-10 was still open as of March 1990.
In our discussions with site employees we asked why a CARR was not written after the test following rework to resolve TE-07 failed to meet the flow acceptance criteria.
The response was that TE-10 could be resolved by.
engineering, revising the design baseline and the acceptance criteria justifying the lower value obtained in the retest.
This second test failure is indicative of an inadequate pump design and this should be documented on a
CARR as required by SOSP-3. 13, paragraph 6.2. 1.A.
Exam le 8 (2 In discussions with the Browns Ferry staff in March 1990 we obtained new information which substantiates that problems associated with the shutdown board room cooling units should have been documented in a
CARR, albeit for slightly different reasons than documented in the Notice of Violation (NOV) and in the details of IR-89-53.
The new shutdown board room cooling units are of significantly greater capacity than the original design, which had difficulty providing adequate cooling.
The new design consists of two independent redundant 30 ton units, which replaced the old design of two 3-5 ton units.
Ouring post-modification test, PMT-161, the 30 ton units tripped when the cooling capacity test was attempted.
It became apparent that the new units were not designed to operate under normal load conditions and the compressor unloader system had to be redesigned in order for the units to operate
to 50 percent loaded.
The failure of the units to operate in order to perform the PMT was caused by an inadequate design and this should have been documented on a
CARR as required by SOSP-3. 13, paragraph 6.2. 1.A.
NRC Conclusion For the above reasons, the NRC staff concludes that the violation occurred, as originally stated.