ML18029A902
| ML18029A902 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/23/1985 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8510070335 | |
| Download: ML18029A902 (23) | |
Text
4 I~
r TENNESSEE VALLEYAUTHOR1TY CHATTANOOGA, TENNESSEE 37401 40+Qestnut Street Tower II p I, J g '$g ~
September 23, 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 NOS. 50-259/85-28, 50-260/85-28, 50-296/85-28
RESPONSE
TO VIOLATION I
Enclosed is our response to R.
D. Walker's June 24, 1985 letter to H. G.
Parris transmitting IE Inspection Report 85-28 for Browns Ferry Nuclear Plant which cited us with four level IV and three level V violations.
On July 22, 1985, I discussed with D. Verrelli an extension for submitting, this response and have discussed this matter with your staff several times during the interim.
We regret the length of delay for submitting this response.
If you have any questions, please get, in touch with R. E. Alsup at FTS t
858-2725.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY Nuclear Licensing Branch Enclosure cc:
Mr. James Taylor, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555
'510070335 805000259
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An Equal Opportunity Employer
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RESPONSE
NRC INSPECTION REPORT NOS.
50-259/85-28, 50-260/85-28, AND 50-296/85-28 ROGER D. WALKER'S LETTER TO H. G.
PARRIS DATED JUNE 24, 1985
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Technical Specification 3.ll.A.1.a. requires that the high pressure fire protection system shall have two high pressure fire pumps,
Contrary to the above, the requirement was not met in that from 1530 on May 21, 1985, to 2130 on May 23, 1985, only one high pressure fire pump was aligned to the high pressure fire header and no compensatory fire watches were posted as allowed by Technical Specification 3.11.A.2.
when only one high pressure fire pump is available.
This is a Severity Level IV violation (Supplement I), and is applicable to all three units.
'ss'o o
en ed at'on TVA admits to the violation as stated.
2.
s s
o t e
'o t'he subject portion of the fire protection system was removed from service on May 20, 1985, to allow for emergency maintenance.
The system was not properly returned to service on May 21, 1985.
Investigation of the event indicates personnel error was the root cause of the event in failing to fully follow the realignment procedure.
3.
C ect e Ste s
'c e
e a e d
es ts c
e ed Upon discovery of the problem on May 23, 1985, the misaligned valves were corrected, and the system returned to normal.
The personnel responsible for the error were disciplined and penalized with time off without pay.
A review of the fire header isolation incident with emphasis on procedural controls and verification of valve positioning was conducted for operations personnel.
4.
Co ect e Ste s
'c e t o'
t e
'o t'o s No further actions directly associated with this event are planned.
5.
te en u
Com
'a ce c
ed Full compliance has been achieved.
10 CFR 50, Appendix B, Criterion V requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, this requirement was not met for the following two examples:
(1) Units 1, 2, and 3 diesel generator battery racks were not seismically mounted as required by TVA drawing 48N897 series.
(2) 3EB shutdown board battery was not seismically mounted as per C and D
installation instructions Section 12-600-1.
1.
d 'ss'o o t e e e o at'o TVA admits the violation as stated.
This item has been reported in BFRO-50-259/85014.
2.
eas s
e
'o t'o Item 2a(l) was caused because modification engineers did not take appropriate steps to ensure all design requirements were met during installation of the battery racks.
The second item was caused by a lack of detailed mounting instructions.
3.
Co ect'te s
ch e
ee a e d
es ts c
ved The diesel generator battery racks were upgraded on April 20 and 21 to meet seismic requirements.
On April 22 the 3EB shutdown board battery rack was modified to meet seismic requirements.
The probability. of similar installation errors occurring has been minimized by the present modification procedures.
The present procedures are more comprehensive than the procedures used to install the battery racks in 1979 and 1980.
4.
Co ec e
te a e to o
u t e
'o at o s No further actions are planned.
5.
t e
Com a ce c 'eyed Full compliance has been achieved.
a b
Contrary to the above, the licensee failed to adhere to Standard Practice 8.3., Plant Modifications, in that Norkplan No. 0049-84 did not list S.I.
4.11.A.5.,
High Pressure Fire Protection System Valve Alignment, as one of the instructions requiring review and updating as a result of a field change request.
Section 8.3.1. of Standard Practice 8.3. requires that plant personnel list any plant instructions requiring revision in Section XII of the workplan control form.
Since the workplan was implementing a field change to the fire protection system drawings, SI 4.11.A.5.
should have been listed among those instructions requiring review and updating.
This is a Severity Level IV violation (Supplement I), and is applicable to all three units.
1.
m ss o
o en o
e e e o
t'on TVA admits the violation occurred as stated.
2.
e s s
o e
o
'o lforkplan 0049-84 was reviewed in the safety section for industrial safety and fire prevention concerns.
The review was inadequate in that the interface with the surveillance instructions was not recognized.
A contributing factor was the absence of a permanent fire protection engineer in the safety staff at the time.
3.
Co ec S e s
'c e
ee e
d es t c 'd SI 4.11.A.5 was revised May 28, 1985, to include required changes.
A separate fire protection engineering unit has been functionally established within the safety section and staffed by a qualified fire protection engineer.
The fire protection unit reviews all wor kplans affecting fire protection systems after safety and other cognizant sections have completed their review.
This review serves as verification that all needed procedure changes are identified.
4.
C ect e
e a e to vo d u t e
'o t No further actions are necessary.
5.
ate e
u Com 'e c 'e ed Full compliance has been achieved.
10 CFR 50, Appendix B, Criterion XVE 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 and that the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, the licensee failed to promptly identify and correct the cause of repeated failures of a 480/120 VAC transformer which supplies power to the Unit 1 Standby Liquid Control (SLC) system piping trace heaters.
The cause of the transformer failures was not identified until February 27, 1985, even though an excessive failure history of six transformers dating back to January 1979 existed for this normally reliable component.
The transformers were found to be overloaded by 39$, a condition which has reportedly existed since original installation.
This is a Severity Level IV violation (Supplement D, and is applicable to Unit 1 only.
l.
m'io o
te ee o
t'VA admits the violation occurred as stated.
2.
e s s
t e o at'o Prior to the February 7, 1985 failure, the maintenance request history program (which was implemented in January 1985) and power stores records were not reviewed.
A review of these records would have indicated a recurring problem with the failure of the unit 1
SLC transformers.
3.
Co ect've te s c
H e
e e
a es ts c
e ed Following the February 7, 1985 failure, the maintenance request history program was reviewed.
This review identified previous SLC transformer failures.
An investigation was initiated, and it was discovered that the wrong size heat trace was installed on unit 1.
The failed transformer was replaced, and the SLC system returned to service.
A modification request has been initiated to install the correct size heat trace.
4.
Co ec Ste a
n to o
u t e o
'o s A failure trending program is being established in the electrical maintenance section.
This program should provide additional assurance that recurring failures are detected.
Com 'e c 'e ed January 15, 1986
Item 4 10 CFR 50.73(a)(2) requires that the licensee shall submit a Licensee Event Report (LER) within 30 days after discovery of any event or condition that alone could have prevented the fulfillment of the safety function of systems that are needed to mitigate the consequences of an accident or that resulted in manual or automatic actuation of an Engineered Safety Feature (ESF), including the Reactor Protection System (RPS).
Exa le 4a Contrary to the above, the licensee failed to submit an LER within 30 days after the discovery of a condition in the Unit 1 Standby Liquid Control (SLC) system that alone could have rendered the SLC System inoperable.
The SLC System is needed to bring the reactor from full power to cold shutdown in the event that withdrawn control rods cannot be inser ted.
On February 27,
- 1985, the licensee determined that the SLC pump suction piping heat trace (both normal and alternate) was oversized by about 39$ resulting in an overload condition on the 480/120 volt AC power supply transformers (the transformers had failed due to the overload at least six times in that last six years).
Failure of the power supply transformers renders the SLC inoperable by allowing the suction piping temperature to cool to below the Technical Specification required limit.
TVA admits the violation as stated.
2.
Reasons For the Violation 10 CFR 50.73 (a)(2)(v) requires reporting of events that alone could have prevented fulfillment of a safety fmction.
Reporting is required if there is reasonable doubt that the functionally redundant train would remain operable until it completes its safety function or is repaired.
In this particular case, the net effect of the heat trace oversizing was a reduction in the reliability of the transformers to the extent that a more frequent than normally expected replacement was required.
Two redundant trace heater systems exi.st and simultaneous loss of both systems due to the reliability reduction was believed unlikely.
We did not recognize that reporting under 10 CFR 50.73 (a)(2)(v) would be necessary.
We also add that the suction piping temperature is physically checked once per shift so an undetected problen with technical specification temperature limits is very unlikely.
Item 0 a (c ontim ed) 3.
Corrective Stq>s lhich Have Been Taken and Remits Achieved An assignment to subnit an LER on this subject has been made.
4.
Corrective Sty>s 'ihich VillBe Tdcen to Avoid Fhrther Violations A menorandum to the engineering, maintenance, compliance, and shift technical advisors sections will be prepared discussing this violation and reportability under 10 (PR 50.73 (a)(2)(v).
H.
Date then Fhll Cocp liame MillBe Achieved The above steps will be completed by October 18F 1985.
S
m e
b Contrary to the above, the licensee failed to submit an LER within 30'ays of an event which occurred on January 16, 1985, in which the Unit 1
autcmatically actuated to scram the reactor on a low reactor water level trip signal.
The High Pressure Coolant Injection System (HPCI) and Reactor Core Isolation Cooling System (RCIC) were also autcmatically actuated during the event.
This is a Severity Level IV violation (Supplement I), and is applicable to Unit 1 only.
1.
m'ss'o o
o t e e
o t'o TVA admits to the violation as stated.
2.
eas s
o t e
'o t o The autcmatic scram was reported to NRC on January 16, 1985, in accordance with 10 CFR 50.72.
- However, due to an administrative handling error in the compliance section, the required 30-day report was not processed.
3.
Co ect e t s
'c e
es t c
d LER BFRO-50-259/85016 was transmitted reportable event determinations since verify that a generic problem did not handling error was discussed with the ensuring processing of LERs.
on May 31, 1985.
A review of January 1985 was conducted to exist.
The administrative personnel responsible for 4.
Co ec Ste s
'c a e to o d t e o t o s No further action is required.
5.
at e
Com 'e c 'e ed Full compliance has been achieved with the'ransmittal of BFRO-50-259/85016.
Item 5 Technical Specification 6.3.A requires that detailed written procedures coverS.ng the itens listed below shall be pre~red,
- approved, and adhered to:
Normal startup, operation, and shutdown of all systens involving nuclear safety of the facility.
Surveillance and testing requirements.
~ana le 5a Contr ary to the above, the licensee failed to prepare adequate procedures for fi.re protection system surveillance requirements in the following exam pl es:
(1) Technical Specification
('S) 4.11.C.5 requires that smoke detector' sensitivity be checked in accordance with manufacturer' instructions.
Surveillance Instruction (SI) 4.11.C.l and C.5, Fire Protection Testing of Smoke and Heat Detectors, was inadequate in that it failed to comply with the manufacturer's instructions contained in Walter Kidde and Can~ny Bulletin 841 "Fire Aler t CPD-1212 Installation and Technical Data".
SI 4.11.C.1 and C.5 was additionally inadequate in that it describes a met)md for testing a Fire Alert Model FT&00 smoke detector which could not be located in the manufacturer' instructions.
TVA admits the violation as stated.
2.
Reasons For the Violation The procedure used to test smoke detector No. CDP-1212 is in accordance with the latest revision of the manufacturer's data sheet (No. FA-101 Revision 5-77).
This data sheet was, however, not available at the time of the S.nspection.
With re@r ds to the FT-200 smoke detector, vendor information could not be provided which demonstrated our conformance to manufacturer's recommendations.
These units are no lon8.r in production and test met1mds sp cified by the last vendor information cannot be utilized because of mavailability of'endor supplied test equipnent.
Both of these problens are reflective of discrepancies caused by lack of adequate vendor information control.
Item 5a continued 3.
Corrective Ste s Which Have Been Taken and Results Achieved As noted above, the latest vendor information for smoke detector No.
CPD-1212 has been provided.
With regards to the FT-200 smoke detector, we have received a vendor letter confirming that our test methods are in accordance with their recommendations.
- Also, we have reviewed our current test method and have determined it is appropriate and conservative.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations A proposed change deleting TS 4.11.C.5 will be submitted.
Deletion of this technical specification enables TVA to maintain and prepare test procedures which can be updated for current standards.
This avoids similar case problems where the detectors are no longer in pro-duction and vendor supplied test equipment or current instructions for testing the detectors may be unavailable.
Implementation of the overall vendor manual program will minimize recurrence of this type violation.
The schedule for this program has been provided in previous correspondence and is being managed as a
separate project.
5.
Date Mhen Full Com liance Mill Be Achieved The proposed change will be submitted by October 31, 1985.
am e
b Contrary to the above, the licensee failed to prepare adequate procedures for the Reactor Core Isolation Cooling System (RCIC) in that the valve checklist contained in Operating Instruction No. 71 Reactor Core Isolation Cooling System, did not include valves71-221 and 71-222.
These are root isolation valves for the RCIC steam flow instrument PDIS 71-lB which initiates a RCIC isolation signal in the event of a RCIC Steam line rupture.
This is a Severity Level V violation (Supplement I), and is applicable to all three units.
1.
m'sso o
e te ee
'o to TVA admits to the violation as stated.
2.
easo s
o t e io at o The valves were inadvertently omitted from the Operations Instructions (OI)-71 valve checklist.
3.
Co ect'te s
c Ha e en en es ts c 'e ed A system walkdown has been conducted, and OI-71 valve checklist has been revised accordingly.
Included in this OI-71. revision is the addition of valves 3-71-221 and 3-71-222.
4.
Co ect e Ste s
'c a e to Avo d u t e
'o t o No further actions directly associated with this event are planned.
5.
Date en u
Com 'e c
ed The OI revision has been completed.
Item 6 Technical Specification 6.2.B.4.e requires that the Plant Operations Review Canmittee (PORC) review reportable events, unusual
- events, oper ating ancmalies, and abnormal performance of plant equi pnent.
Ccntrary to the above, as of May 14, 1985, the Plant Operations Review Ccrnmittee failed to review two events which occurred in January 1985, that were classified as Notification of Unusual Events (which indi.cated abnormal performance of plant e~ipnent) in accordance with the licensee's Radiological Emergency Plan.
These two events occurred on Unit 1 and involved the inoperability of the contairment cooling mode of the Residual Heat Renoval System on Janunr y 9, 1985, and the inoperaMlity of the Standby Liquid Control System on January 11, 1985.
This is a Severity Level V violation (Kpplenent I), and is applicable to Unit 1 only.
TVA admits that the Plant Operations Review Ccmmittee (PORC) did not review two events that occurred on January 9, 1985, and January 11,
- 1985, whi.ch were classified ader TVA's emergency plan classification 1 ogL c as a
Notificati on of Unus ural Event, IP -2.
2.
Reasons For the Violation In these two events, one involving standby liquid control systen (SLC) operabLlity (TS 3.4.D) and the other involving residual heat removal systen (RHR) operability ('S 3. 5. B.4), unit 1 was placed in a 24-hour limiting condition for operation.
In both cases, this was due to a maintenance problen wi.th one component, and the onsite diesel 8 nerator being unavailable for the redundant or second component.
Although not imnediately recpired by TSs, the shift engineer initiated a load reduction in anticipation of removal of the unit from servLce.
This prompted the declaration of an IP<, Notification of Unusual Event, even thatch the point of a mandated load reduction had not been reached due to a TS limiting condition for operation (LG3) time limit.
In both
- cases, the re~ired systen components were made operable to secure from the IP< well before the end of the 24-hour LG).
The January 9, 1985 event on the RHR systen ended 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and 35 minutes into the 24-lour clock.
The January ll, 1985 event on the SLC system ended 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 4
minutes into the 24-hour clock.
TS 6.2.B.4.e states that PORC will "review reportable events, unusual events, operating ancmalies, and alnormal performance of plant e<pipnent."
Our ener0'.ncy classification logLc defines the Notificaticrr of Unmml Event categpry as "..
~ early and prompt notificaticn of minor events which couid develop into, or be indicative of more serious conditions which are not yet realized."
We failed to recognize that events ader this emer8.ncy classification desigpation were considered included in the technical specification cate~ry for PORC review.
Item 6 (c ontim ed) 3.
Corra.'tive Stq)s lhinh Have Been Taken and Remits Aohieved The Radiologi.cal Emer8.ncy Plan has been revimed to determine the necessary chan8.'s to ensue PORC review.
Correo tive Stq>s 'Ihioh WillBe Tacan to Avoid Farther Violations Procedures will be revised to re(pire PORC review of IP-2 (Unmml Events),
1P-3 (Alerts),
3P-4 (Site Area Emer8.ncy),
and IP< (General Emer8 ncy).
5.
Date %en Fall Corp>lian.e WillBe Aohieved These chan8:s will be approved by November 5, 1985.
10 CFR 50, Appendix B, Criterion II requires that the quality assurance program be carried out in accordance with written policies, procedures, or instructions.
Contrary to the above, the licensee failed to carry out the quality assurance program in accordance with written policies, procedures, or instructions in that no evaluation for reportability under 10 CFR 21 was performed in accordance with Browns Ferry Standard Practice 15.23, (10 CFR 21 Evaluation and Reporting Requirement).
The licensee was informed by the manufacturer of a generic problem with the main steam relief valve acoustic flow monitor (TEC 914 Module) that the circuit malfunction experienced by the licensee during a scram on January 16, 1985, was attributed to overdriving of the bar graph driver chip.
This is a Severity Level V violation (Supplement I), and is applicable to all three units.
1.
dm'ss'o o
D n' e
e ed
'o at'o TVA admits the violation that evaluation for reportability under 10 CFR 21 was not performed.
2.
e s s
o t
'o o
Standard Practice 6.18 (Failure Investigations of Safety Related Items) was incomplete in that it did not require the evaluation.
3.
Co ect've Ste s
c a e e
a e a d esu ts c
e ed A Part 21 report was completed on May 31, 1985.
The problem was determined not to be generic.
Further consultation with the vendor continued, and in June 1985 TEC notified TVA that the problem was not generic and recommended additional testing.
Based on TVA's test results (5 of 47 circuit cards exhibited the circuit malfunction),
TEC concluded that certain batches of the circuit cards could be subject to this malfunction.
TEC notified NRC of the potential quality problem on July 18, 1985, and TVA on July 23, 1985.
LER BFRO-50-259/85016 is being revised to include details of our testing and corrective actions for the circuit cards.-
4.
C ect've Ste s
'c a e o'd u t o t o s Standard Practice 6.18 will be revised to require an evaluation for repor tability requirements.
5.
e C
m c
eyed Full compliance has been achieved.
P