ML18029A590
| ML18029A590 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/19/1985 |
| From: | Shell R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8506210485 | |
| Download: ML18029A590 (18) | |
Text
TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 4g g, g(estngf Ptt d$t Tower II g5 QYI(
April 19, 1985 U.S. Nuclear Regulatory Commission Region II ATTN:
Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Dear Dr. Grace:
BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 - NRC-OIE REGION II INSPECTION REPORT 50-259/85-06,
-260/85-06,
-296/85 RESPONSE TO VIOLATION Enclosed is our response to your March 19, 1985 letter to H. G. Parris transmitting IE Inspection Report Nos. 50-259/85-06, 50-260/85-06, and 50-296/85-06 for our Browns Ferry Nuclear Plant which cited TVA with five Severity Level IV Violations.,
1t An extension of the submittal deadline,to April 22, 1985 was discussed with Floyd Cantr ell of your staff on April 18, 1985.
If you have any questions, please get in touch with R. E. Alsup at FTS 858-2725.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY 4 (4.
R.
H. Shell Nuclear Engineer Enclosure cc (Enclosure):
Mr. James Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Records Center Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 85OSai048S 8504f9 PDR ADOCK 05000259 Q
PDR An Equal Opportunity Employer
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RESPONSE
NRC INSPECZION REPORT NOS.
50-259/85-06, 50-260/85-06, AND 50-296/85-06 J.
NELSON GRACE' LETTER TO H.
G.
PARRIS DATED MARCH 19, 1985 Enclosure 1
Item 1 Technical Specification 3.5.E. 1(2) requires that the high pressure coolant injection (HPCI) system shall be operable whenever there is irradiated fuel in the reactor vessel, and the reactor pressure is greater than 122 psig.
Contrary to the above, this requirement was not met in that HPCI was not operable during all power operations from December 19, 1984 until January ll, 1985, due to the inability to reach rated flow in less than 25 seconds as described in Final Safety Analysis Report (FSAR) Section 7.4.3.2.5.
HPCI was declared inoperable on January 11,
- 1985, when the time to reach rated flow was noted to be 35 seconds during surveillance test Surveillance Instruction (SI) 4.5.E.1.
This is a Severity Level IV violation (Supplement I) applicable to unit 3.
l.
Admission or Denial of the Alle ed Violation TVA admits the violation as stated.
2.
Reasons For the Violation HP(X would not meet the FSAR startup time requirement of 25 seconds because of incorrect adjustment of the turbine steam supply valve limit switch which starts the auxiliary oil pump during the auto start sequence.
The incorrect setting of the limit switch was due to a
drawing error and i,s discussed in the response to violation S.a of this repor t.
The root cause of HPCI inoperability from December 19,
- 1984, to January 11,
- 1985, was inadequate post maintenance testing specification following maintenance performed on the turbine steam supply valve on December 9, 1984.
HPCX inoperabil ity was proven on December 11,
- 1984, by performance of Surveillance Instruction (SI) 4.5.E.2.d and e HPCI System turbine and pump flow test using auxiliary boiler steam.
This test is used when the reactor is shut down and does not demonstrate startup time.
SI 4.5.E. l.d and e, which tests HPCI startup time using reactor
- steam, was not specified for post maintenance testing.
During the next scheduled performance of SI 4.5.E.l.d and e, the startup time was found to be out of limit.
3.
Corrective Ste s Which Have Been Taken and Results Achieved The limit switch for unit 3 HPCX steam supply valve was set correctly and the auto initiation time requirement of 25 seconds was proven by performance of SI 4.5.E. l.d and e
on January 12, 1985.
The HPCI steam supply valves on the other units were inspected.
Unit 2 HPCI steam supply valve was found to be set correctly.
The unit 1 HPCI steam supply valve was found to be set incorrectly.
Previous surveillance
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Page 2
Item 1 Continued instruction data for unit 1 had shown the startup time requirement of 25 seconds to have been met;
- however, the SI (4.5.E. l.d and e) was found to be unclear in the method used to measure HPCI startup time.
This is discussed in the response to violation 5.c of this report.
On January 18,
- 1985, the unit 1 limit switch on the HPCZ turbine steam supply valve was se t correctly, and auto start time requirement of 25 seconds was redemonstrated by performance of SX 4.5.E. l.d and e
on January 25, 1985.
The drawing error for the HPCX turbine steam supply valve limit switch has been corrected.
SI 4.5.E, l.d and e will be specified as part of post maintenance testing requirements for any maintenance performed on the HPCI steam supply valve which could affect HPCI startup time.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations SI 4.5.E will be revised to clarify the conditions under which the SI is performed on auxiliary boiler steam and nuclear steam.
5.
Date When Full Com liance Will Be Achieved Full compliance will be achieved by May 17, 1985.
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Item 2 10 CFR 50, Appendix B, Criterion XVI requires that measures shall be established to assure that conditions adverse to quality are promptly identified, corrected and action taken to preclude repetition.
Contrary to the above, the action taken to preclude repetition of a previously identified condition adverse to quality was inadequate in that thermometers stocked by power stores did not have factory certification traceable to the National Bureau of Standards or to Industry Standards as required by Browns Ferry (BF) Standard Practice 17.19,
'Program to Establish and Maintain Certifiably Accurate Thcrmcinetcrs. 'F 17.19 was implemented in response to a previous violation (Violation 259, 260, 296/82-34-06),
and it requires that instruments used in activities affecting quality be properly controlled and calibrated.
The following
'xamples of thcrmomcters used in performing surveillance instructions were found:
a.
Twelve rcd organic liquid, 0-230 degrees F, self-indicating thermomctcrs ordered under Requisition No. 355667, dated July 19, 1984.
b.
Sixty liquid in glass,
(-20)-120 degrees F, self-indicating thexmometers ordered under Requisition No. 351094, dated June 27, 1984.
c.
Four bimetallic, range 0-240 degrees F, self-indicating thermometers ordered under Requisition No. 934217, dated October 25, 1983.
This is a Severity Level IV violation (Supplement I) applicable to Units 1, 2p and 3
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1.
Admission or Denial of the Alle ed Violation TVA admits to thc violation as stated.
2.
Reasons For the Violation Certification papers were not found for all of the thermometers listed in the violation.
During thc investigation a problem was found with thc administrative controls associated with thcrmometcr procurement and use.
Some certified thermometers werc being used for other purposes and were sent offsite for periodic certification.
%he existing administrative controls failed to reflect all methods being used to certify thermometers.
They also failed to ensuxe that only certified thermometers were used since all thermometers procured at the plant were not certified.
A program is in place as a rcsul t of violation 259, 260, 296/82-34-06 establishing procurement controls;
- howcvcr, a
deficiency existed in Standard Practice BF 17.19 that could allow power stores to dispense a non-certified thermometer for use in a surveillance instruction.
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Item 2 Continued 3.
Corrective Ste s Which Have Been Taken and Results Achieved Administrative controls arc being revised to reflect actual practices being used to certify thermometers for technical specification requirements.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations Thermometers in stock at the plant will be reviewed to determine which axe certified.
Additionally, a procedure to certify thermometers against a standard thermometer prior to issuance from stores is being implemented.
Standard Practice BF 17.19 will be revised to further ensure that only certified thermometers arc used in support of technical specif ication data collection.
An unreproachablc means of preventing reoccurcnce of this problem is being pursued.
5.
Date When Full Com liance Will Be Achieved Full compliance will be achieved by August 31, 1985.
Page 5
Item I Technical Specification 3.7.D.1 requires that during reactor power operation, all isolation valves listed in Table 3.7.A. shall be operable.
Table 3.7.A requires core spray system check valve FCV 75-26 to be op era bl e.
Contrary to the above, this requirement was not met in that during reactor power operation on January 21,
- 1985, FCV 75-26 was inoperable due to the installation of a test hose which bypassed and equalized flow around the testable check valve.
The isolation valves to the test hose had been left open during recent surveillance activities on the core spray system (SI 3.2.2).
This is a Severity Level IV violation (Supplement I) applicable to unit 1.
l.
Admission or Denial of the Alle ed Violation TVA admits to the violation as stated.
2.
Reasons For the Violation Surveillance Instruction (SI) 3.2.2 allows for the use of a bypass hose to equalize pressure across core spray testable check valves.
- However, the procedure was inadequate in not specifying removal of the hose and the return of test connection valves to the closed position after comple tion of test.
3.
Corrective Ste s Which Have Been Taken and Results Achieved Upon detection of drywell leakage, the reactor was shutdown and a
drywell entry was made.
The bypass hose was removed, and the test connection valves were returned to the normally closed position.
SI 3.2.2 has been revised to reference Mechanical Maintenance Instruction (MMI)-51 for installation and removal of pressure equalizing bypass hose.
Appropriate instructions and signoffs have been added to bM-51 to ensure that hose removal is completed and documented during the test.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations No further corrective action is planned.
5.
Date When Full Com liance Will Be Achieved Full compliance was achieved on January 29, 1985.
Page 6
Item 4 Technical Specification 3.1.A requires that when the reactor is shutdown with the reactor mode switch in 'Refuel'hat the Intermediate Range Monitor(IRM) high flux scram be operable with three operable channels per trip system.
Contrary to the above, on January 18,
- 1985, the IRhf Channels 'A'nd
'C'ere inoperable in reactor protection trip system 'A'eaving only two channels, 'E'nd 'G', operable in thc respective trip system.
This is a Severity Lovel IV violation (Supplement
.I) applicable to Unit l.
'I I.
Admission or Denial of the Alle ed Violation TVA denies the violation.
Note 1.A for Technical Specification Table 3.1.A can be followed when the minimum number of operable instrument channels per trip system cannot be met for both tri.p systems.
'In refueling mode,'t states,
'suspend all operations involving core alterations and fully insert all operable control rods within one hour.'Ihese requirements were met.
2.
Reasons For the Violation N/A 3.
Corrective Ste s Which Have Been Taken and Results Achieved N/A 4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations N/A 5.
Date When Full Com liance Will Be Achieved N/A
Page 7
Item 5 10 CFR 50, Appendix B, Criterion V requires 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, this requirement was not met for the following five examples:
Examples a through e constitute a single Severity Level IV violation (Supplement I) applicable to all units.
Exam le a Item 5 TVA drawing 45N714-2 was inadequate in that a note used to set the limitorque valve limit switches, which initiated the starting of the HPCI system auxiliary oil pump when the steam isolation valve (FCV-73-16) was full open was in error.
This error resulted in HPCI not meeting its design flow in less than 25 seconds as stated in FSAR Section 7.4 l.
Admission or Denial of the Alle ed Violation TVA admits to the violation as stated.
2.
Reasons For the Violation The limit switch on 3-FCV-73-16 was set utilizing an approved procedure and an engineering design issued and controlled drawing.
The drawing had conflicting notes for the limit switch being set, and the limit switch was set according to the incorrect note.
3.
Corrective Ste s Which Have Been Taken and Results Achieved Deficiency Report 85-0079 was initiated January 15,
- 1985, to correct drawing 4SN714-2.
TVA drawing 45N714-2 was corrected and issued on bfarch 12, 1985.
The limit switch was reset, and the startup time was verified by performance of SI 4.5.E.1. d and e.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations No further corrective action is planned.
5.
Date When Full Com Iiance Will Be Achieved Full compliance was achieved when the revised drawing was issued on hfarch 12, 1985.
Page 8
Exam le b Item 5 SI 4.5.E,2.
d/e, High Pressure Coolant In) ection (HPCX) Turbine and Pump Flow Test (Auxiliary Steam),
was inadequate to verify the ability of HPCI to reach design flow in less than 25 seconds as required by FSAR Section 7.4.
This instruction was used to meet Technical Specification 4.5.E.1 and to verify HPCX operability on December ll, 1984, after maintenance of a valve FCV 73-16.
1.
Admission or Denial of the Alle ed Violation TVA admits to the violation as stated.
2.
Reasons For the Violation Surveillance Instructions were unclear as to which operability test should be performed after mai,ntenancc on FCV 73-16.
3.
Corrective Ste s Which Have Been Taken and Results Achieved Surveillance Instxuction (SI) 4.5.E.1
- d. and e will be used as a post maintenance test any time that maintenance work has been performed on FCV-73-16 which could effect rated flow timing.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations HPCI and reactor core isolation cooling (RCIC) surveillance instructions will be revised to incorporate instructions defining when a flow test is required after maintenance.
5.
Date When Full Com liance Will Be Achieved Full compliance will be achieved by hfay 17, 1985.
Page 9
SI 4.5.E. I. d/e, HPCI Turbine and Pump Flow Test (Reactor Steam) was inadequate in that the timing of HPCX to reach design flow in 25 seconds was not verified as per FSAR Section 7.4.
This SI required timing between the start of the initiation signal to the meeting of the design flow rate.
l.
Admission or Denial of the Alle ed Violation TVA admits to the violation as stated.
2.
Reasons For the Violation Adequate instructions were not contained in SI 4.5.E. l. d and e to define the correct timing interval by which rated flow should be a chi eve d.
3.
Corrective Ste s Which Have Been Taken and Results Achieved SI 4.5.E. 1. d and e
and SI 4.5.F. l.d and e
(HPCI 5 RCIC flow test respectively) have been revised to clarify thc start/stop points of the timing requirement to rated flow.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations No further corrective action is required.
5.
ate When Full Com liance Will Be Achieved Full compliance was achieved on January 21, 1985.
Page 10 SI 3.2.2, Motor Operated Valve Cycling During Cold Shutdown, was inadequate in that Attachment A, Test Methods Testable Check Valves, does not contain steps or signoff steps for the removal of temporary bypass hoses used to equalize pressure across the test valves or for the operation of the valves conne cting the bypass ho se.
1.
Admission or Denial of the Alle ed Violation TVA admits to thc viola tion as stated.
2.
Reasons For the Violation See response to item 3.
3.
Corrective Ste s Which Have Been Taken and Results Achieved See response to item 3.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations Sec response to item 3.
5.
Date When Full Com liance Will Be Achieved See response to item 3.
Page 11 Exam Ie e Item 5 SI 3,2.2, Attachment A,
was not adhered to on January 21, 1985 in that the completed Unit I SI indicated core spray testable check valve 75-26 was tested using method I (cycle valve with actuator from control room), but method 3 (bypass hose) was used instead.
The operator was unaware a bypass hose had been connected.
The SX procedure did not note other hoses connected for thc HPCI and recirculation 'systems either, although they were use di l.
Admission or Denial of the Alle ed Violation TVA admits to the violation as stated.
2.
Reasons For the Violation A lack of communication had dcvcloped between operations and maintenance sections during the testing of FCV 75-26.
3.
Corrective Ste s Which Have Been Taken and Results Achieved As stated in item 3, the temporary bypass hose will be installed only by a maintenance request and mechanical maintenance instruction-51.
This instruction package will require review by operations and their assistance in opening/closing test connection valves.
4.
Corrective Ste s Which Wil Be Taken to Avoid Further Violations No further corrective action is rcquircd.
5.
Date When Full Com liance Will Be Achieved Full compliance was achicvcd on January 29, 1985, with issuance of a revised mechanical maintenance instruction-51.
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