ML18029A912
| ML18029A912 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/27/1985 |
| From: | Shell R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8510180021 | |
| Download: ML18029A912 (24) | |
Text
TENNESSEE VALLEYAUTHORITY CHATTANOOGA, TENNESSEE 37401'j" 400 Chestnut Street Tower II 4n September 27, 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
-36, 50-260/85-36, 50-296/85-36
RESPONSE
TO VIOLATION Enclosed is our response to R.
D. Walker's August 7, 1985 letter to H.
G, Parris transmitting IE Inspection Report Nos. 50-259/85-36, 50-260/85-36, and 50-296/85-36 for our Browns Ferry Nuclear Plant which cited TVA with three Severity Level IV Violations, one Severity Level V Violation, and one Deviation.
On September 11 Jim Domer discussed with Dave Verrelli of your staff an extension for submitting, this response.
t 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 R. H. Shell Nuclear Engineer Enclosure cc:
Mr. James Taylor, Director (Enclosure)
Office,of Inspection and Enforcement U.S.
NucleaL Regulatory Commission Washington, D.C.
20555 8510180021 850927 PDR ADOCK 05000259 8
PDR An Equal Opportunity Employer
II S
ENCLOSURE
RESPONSE
NRC INSPECTION REPORT NOS.
50-259/85-36, 50-260/85-36, AND 50-296/85-36 ROGER D. WALKER'S LETTER TO H.
G.
PARRIS DATED AUGUST 7, 1985 Item 1 Technical Specification 6.3.A requires that detailed written procedures covering, the following items shall be prepared, approved and adhered to:
. Normal startup, operation and shutdown of all systems involving nuclear safety of the facility.
. Action to be taken to correct specific and foreseen potential malfunctions of systems or componentse Fire protection and prevention procedures Contrary to the above, this requirement was not met for the two examples that follow:
Exaale la The licensee failed to prepare adequate written procedures covering the unit cross-connection feature of the ReSidual Heat Removal (RHR) System as described in paragraphs 4.8.6.4 and F.7.16 of the Final Safety Analysis Report (FSAR).
This cross-connection feature allows each unit access to one RHR loop belonging to its physically adjacent unit in order to remove decay heat and residual heat from the reactor core and primary containment in the event of a complete failure of the affected unit's emergency core cooling systems (ECCS).
The licensee's existing procedure, Operating, Instruction 74, Residual Heat Removal System, was inadequate in that paragraph IV.F, Cross Connecting Between Units, was limited for use in the containment cooling mode only and did not address the reactor core cooling mode.
The procedure was additionally inadequate in that it did not require the bypassing of certain RHR suction valve interlocks in the RHR pump start circuitry which would prevent the pumps from starting in the specified cross-tie valve lineup.
l.
Admission or Denial of the Alle ed Violation TVA admits tW violation.
2.
Reasons For the Violation All necessary procedural requirements for establishment of the RHR crosstie configuration were not incorporated into plant instructions.
This particular alignment would be utilized in the extremely rare case of losing all ECCS on a given unit.
Page 2
3.
Corrective Ste s Which Have Been Taken and Results Achieved A technical review of the RHR crosstie alignment requirements has been performed to determine required steps for alignment and operation of the RHR crosstie feature as described in the FSAR.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations The RHR system Operating Instruction (OI)-74 will be revised to fully incorporate required steps to crosstie RHR loops.
5.
Date When Full Co liance Will Be Achieved OI-74 will be revised prior to the unit 2 startup.
l~
Page 3
~xaXle 1b The licensee failed to adhere to Operating Instruction 26, High Pressure Fire Protection System for the required system valve lineup.
On June 17,
- 1985, deluge system drain valve 1-26-77-SD was found mispositioned to the open position.
The master valve status checklist in the control room indicated the valve was shut which was contrary to the as-found position.
This is a Severity Level IV Violation (Supplement I) applicable to all three units.
l.
Admission or Denial of the Alle ed Violation TVA admits the violation.
2.
Reasons For the Violation TVA failed to adequately follow procedures that returned the fire protection system to service.
We have not been able to specifically determine when the error was made.
3.
Corrective Ste s Which Have Been Taken and Results Achieved
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On discovery, the valve was closed.-
The operating and surv
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eillance instruct*ons governing the ala.gnment and posx,tion verxfication of this type valve were reviewed and determined to be adequate.
We have concluded that this mispositioning was a random procedural error.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations This violation will be discussed with operations personnel during supplemental training.
5.
Date When Full Com liance Will Be Achieved Full compliance will be achieved by December 1,
1985, following completion of training.
l
Page 4
Item 2 10 CFR 50, Appendix B, Criterion V requires that activities affecting quality shall be prescr ibed by drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these drawings.
Contrary to the above, the requirement was not met in that the High Pressure Coolant Infection System torus suction valve, 73-27, was not electrically connected in accordance with TVA drawings 45N714-2RB, 45N3711-3RA, and 45N3711-5RA.
This is a Severity Level IV violation (Supplement I) and is applicable to Unit Three.
1.
Admission or Denial of the Alle ed Violation TVA admits the violation.
2.
Reasons For the Violation The valve had been wired incorrectly since preoperational testing.
Apparently, the armature leads were reversed at the motor.
In order to maintain correct motor rotation, the series and field windings were reversed at the reactor motor operated valve board.
This wiring configuration permitted the unit 3 valve to close faster than if wired.
per TVA drawings.
3.
Corrective Ste s Which Have Been Taken and Results Achieved An analysis and a special test were performed on valve 3-FCV-73-27 with the motor incorrectly wired.
This showed that the valve would have performed its intended function and that the operability of the valve was not degraded as a result of the incorrect wiring.
Valve 3-FCV-7~-
27 has been wired correctly and now operates at approximately the sa~
speed as the identical valves on units 1
and 2.
All valves with timing criteria have been reviewed for consistency of identical valves.
2-FCV-74-30 and 2-FCV-74-57 were noted to have timing inconsistencies.
Corrective Ste s Which Will Be Taken to Avoid Further Violations An investigation will be performed to determine why 2-FCV-74-30 and 2-FCV-74-57 appear to have timing discrepancies.
Surveillance Instruction (SI) 4.5.E.1.c will be revised to reflect the new timing ct iteria for 3-FCV-73-27.
5.
Date When Full Com liance Will Be Achieved The investigation and any required corrective action on valves 2-FCV-74-30 and 2-FCV-74-57 will be performed prior to the startup of unit 2.
SI 4.5.E.1.c will be revised prior to unit 3 startup to reflect 3-FCV-73-27 timing criteria.
Page 5
Item 3 Technical Specification 6.3.A. requires that detailed written procedures, including applicable checkoff lists, shall be prepared,
- approved, and adhered to for system operation and corrective maintenance which could have an effect on the safety of the reactor.
Procedures were not adhered to or were inadequate in the following examples:
~Exam la 3a Mechanical Maintenance Instruction (MMI)-28, Control Rod Drive Hydraulic Unit (Repair,
- Removal, and Replacement),
Step 6.3 requires that the maintenance request contain the functional and post maintenance test requirements as specified in the MMI Testing Section and that the maintenance foreman ensure these test requirements are performed and signed off.
Contrary to the above, MR A126652, completed February 20,
- 1985, on Unit 1 Control Rod Drive Module 34-03 did not contain the functional and post maintenance test requirements consisting of insertion and withdrawal timing.
Additionally, the responsible foreman did not ensure the required testing was performed and signed off.
l.
Admission or Denial of the Alle ed Violation TVA admits the violation.
2.
Reasons For the Violation The reason for the violation was personnel error as evidenced by failure of the foreman and general foreman to follow procedures.
- Also, MMI-28 was not clearly written and did not adequately cross reference applicable sections within the procedure.
3, Corrective Ste s Which Have Been Taken and Results Achieved Appropriate disciplinary action was taken with the involved personnel.
MMI-28 has been revised for cross referencing, and clarity.
4, Corrective Ste s Which Will Be Taken to Avoid Further Violations No further action is planned.
5.
Date When Full Com liance Will Be Achieved Full compliance has been achieved.
Page 6
~Exam le 3b MMI-28, Section 10.3, and Browns Ferry Operating Instruction (OI)-85, Control Rod Drive System, Section 3.H.1.e.2.e.,
require that control rod insertion and withdrawal times be 48 plus or minus 3 seconds.
Contrary to the above, during control rod timing checks on February 22,
- 1985, rod withdrawal and insertion times of 41 and 53 seconds respectively for Unit 1 Control Rod 34-03 were accepted as satisfactory.
l.
Admission or Denial of the Alle ed Violation TVA admits the violation..
2.
Reasons For the Violation Refueling Test Instruction
( RTI)-5 (Control Rod Drive System) specifies that normal insert and withdraw speed will be indicated by a full stroke taking 40-60 seconds.
The tolerance of 40-60 seconds is consistent with vendor recommendations and was the acceptance cr iteria used on February 22, 1985, during control rod timing checks.
Therefore, based on this procedure, control rod 34-03 was accepted as satisfactory.
MMI-28 and OI-85 required control-rod insertion and withdrawal time to be 48 plus or minus 3 seconds.
There was a failure to ensure consistent criteria was included in the three procedures.
3.
Corrective Ste s Which Have Been Taken and Results Achieved The timing criteria in MMI-28 and OI-85 were determined to be overly restrictive and have been revised to reference the control rod insertion and withdrawal times given in RTI-5.
The three subject procedures now have consistent timing criteria.
Corrective Ste s Which Will Be Taken to Avoid Further Violations N/A 5.
Date When Full Com liance Will Be Achieved Ful3 compliance has been achieved.
Page 7
E~xam le 3c OZ-85, Section 3.D.9, requires that if control rod drive water pressure is ~
increased above normal limits (260 psi greater than reactor pressure) to initially move a rod from the fully inserted position, then it. should be returned to normal before a rod passes the 02 notch position in order to prevent double notching in a high rod worth regions.
I Contrary to the above, on February 22, 1985, Unit 1 control rod 34-03 was withdrawn past notch position 02 with drive water pressure approximately 50 psi above normal limits.
l.
Admission or Denial of the Alle ed Violation TVA admits the violation.
2.
Reasons For the Violation OZ-85 was too restrictive in its limitations of control rod drive pressure and control rod position which resulted in an inadvertent failure to follow procedures.
3.
Corrective Ste s Which Have Been Taken and Results Achieved
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OZ-85 will be revised to permit drive pressure to remain above normal levels until notch 06 is reached.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations As described in item 3.
5.
Date When Full Co lienee Full compliance t:ill be achieved by October 4, 1985.
40 i
Page 8
~Exam le Ed Standard Practice 17.18 requires a safety evaluation of changes to safety related equipment that remain following completion of a maintenance activity to provide the basis for a determination that the change did not involve an unreviewed safety question.
Contrary to the above, this requirement was not met in that, when failed open resistors on both High Pressure Coolant Infection (HPCI) steam line drain isolation valves'73-6A and 73-6B) solenoid field suppression circuits were found during maintenance activity on March 8, l985, no safety evaluation was performed to determine the operability of the HPCI system under this potentially degraded condition.
The resistors were not replaced and the HPCI system was not evaluated during power operation until the unit was shutdown on March 19, 1985.
This is a Severity Level IV violation (Supplement I) and is applicable to all units.
l., Admission or Denial of the Alle ed Violation TVA admits the violation.
2.
Reasons For the Violation The cognizant engineer and electrical maintenance group supervisor performed an undocumented engineering evaluation when the problem was'dentified.
Their conclusion, that HPCI operability was not affected, was verified by the formal evaluation of the HPCI circuitry.
3.
Corrective Ste s Which Have Been Taken and Results Achieved A formal evaluation assessing HPCI operability was completed on March 29, 1985.
This evaluation confirmed that HPCI operability had not been affected by the open resistors.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations The violation is being discussed with electrical maintenance eleMricians and engineers to stress that a safety evaluation is required when changes to safety related equipment remain following maintenance activities.
The remaining HPCI and reactor core isolation cooling solenoid valve suppression networks are being inspected and evaluated.
Any required corrective action will be completed prior to the startup of each applicable unit.
5.
Date When Full Com liance Will Be Achieved The violation will be discussed with electricians and engineers by October 1, 1985.
All corrective action required as a result of inspections and evaluation will be achieved prior to the star tup of the applicable unit.
Page 9
Item 4 10 CFR 50, Appendix B, Criterion XII requires that measures shall be established to assure that measuring and test equipment (ATE) used in activities affecting quality are properly controlled,"'calibrated, and adjusted at specified per iods to maintain accuracy within necessary limits.
Part III, Section 3.1 of the TVA Nuclear Operations Quality Assurance Manual (N-OQAM) implements these requirements.
Contrary to the above, the licensee failed to adhere to the requirements of Part III, Section 3.1 of the N-OQAM as indicated by the following examples:
~Exam la ta The accountability of the utilization of the NkTE used as working standards by the Mechanical Maintenance small tool repair and calibration shop was not documented as required by paragraph 2.3.2 of the N-OQAM.
l.
Admission or Denial of the Alle ed Violation TVA admits the violation.
2.
Reasons For the Violation--
The mechanical maintenance small tool repair and calibration shop maintained records of all tools calibrated but did not have a direct method of correlating the calibration standard to the tool calibrated.
This was the result of a failure 4o fully implement the Nuclear Qual':y Assurance Manual (NQAM) requirements into procedures used by mechanical maintenance personnel.
3.
Corrective Ste s Which Have Been Taken and Results Achieved All calibration standards in the mechanical maintenance small tool repair and calibration shop'now have a log in which the identification number of each tool calibrated by the standard is recorded.
The dam~
of calibration is also recorded; 4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations A procedure is being written for the mechanical maintenance small tool repair and calibration shop which delineates the NQAM requirements.
5.
Date When Full Com liance Will Be Achieved The logs are being maintained at the present time.
All procedures will be in place by October 30, 1985.
Page 10
~Exam le 4b The assigned calibration interval for RITE was not adequately based upon experience available through historical calibration performance r ecords as required by paragraph 3.2.1 of the N-OQAM in the following two examples:
1.
Oscilloscope number 251425 was found out-of-tolerance on its last five annual calibrations (ll/5/80, 10/26/81, 10/19/82, 10/21/83 and 10/19/84), yet, each out-of-tolerance investigation report either did not address the calibration interval or concluded that the interval was adequate.
2.
Pressure gage number E00895 was found out-of-tolerance on two consecutive semi-annual calibrations (2/29/84 and 8/28/84), yet, the out-of-tolerance investigation reports failed to address the adequacy of the calibration interval as required by the out-of-tolerance notice.
This is a Sever ity Level V Violation (Supplement l) applicable to all 3 units.
l.
Admission or Denial of the Alle ed Violation TVA admits the violation.
2.
Reasons For the Violation Failure of maintenance personnel to follow procedures.
Electrical maintenance uses the oscilloscope for troubleshooting and rough measurements only.
3.
Corrective Ste s Which Have Been Taken and Results Achieved Pressure gauge E00895 has been retired.
The mechanical maintenance shop has reviewed the history of all CSSC tools and increased inspection frequency when applicable.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations Mechanical maintenance personnel involved in the review of out-of-calibration ATE will be instructed to review the calibration history of instruments and revise calibration schedules when it is required.
Oscilloscope 251425 will have administrative controls placed on it in order to prevent its use as a calibration tool for CSSC instruments.
5.
Date When Full Com liance Will Be Achieved The personnel have been instructed.
Administra tive controls on the oscilloscope will be in place by September 30, 1985.
DEVIATION Final Safety Analysis Report Section 10.11.5.1, Fire Protection System Seismic Analysis requires that failures of the non-seismically designed High Pressure Raw Water Fire Protection System in the Reactor Building will be detected by two seismically qualified means.
Water level switches six inches off the floor in the torus area, High Pressure Coolant InJection room and the Reactor Core Isolation Cooling room are one of the means.
Contrary to the above, the flood level switches were found not fully operable and not seismically qualified.
The level switches have not been periodically tested since or iginal construction.
Three out of eighteen would not pass an operational test.
This deviation is applicable to all three units.
1.
Cor rective Ste s Which Have Been Taken and Results Achieved All level switches have been tested.
A design change request has been written in order to provide detailed seismic mounting requirements.
Electr ical Maintenance Instruction-90 (Reactor Building and Residual Heat Removal Service Water Pump Rooms Flood Level Switches Functional Test) has been put on a preventive maintenance schedule.
2.
Corrective Ste s Which Will Be Taken to Avoid Further Violations All level switches will be seismically mounted prior to the star tup of the applicable unit.
3.
Date When Full Com liance Will Be Achieved Each unit will be in full compliance before the star tup of that unit.
0