ML18030A973
| ML18030A973 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/18/1985 |
| From: | Parris H TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18030A974 | List: |
| References | |
| NUDOCS 8601030298 | |
| Download: ML18030A973 (19) | |
Text
TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 6N 118 Missionary Ridge Place December 18, 1985 U.S. Nuclear Regulatory Commission Region II ATTN:
Or. J.
Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Dear Dr. Grace BROWNS FERRY NU PLANT UNITS 1, 2, ANO 3 NRC-OIE REGION II INSPECT~
REPORT 50-259/ 5-4
, 50-260/85-45, 5
96/85-45
RESPONSE
TO VIOLATION Enclosed is our response to R.
D. Walker's October 28, 1985 letter transmitting IE Inspection Report Nos.
50-259/85-45, 50-260/85-45, and 50-296/85-45 for our Browns Ferry Nuclear Plant which cited TVA with three Severity Level IV Violations.
Enclosure 2 contains our safety evaluation of the diesel generator battery packs seismic qualification and a discussion on diesel generator vendor manual maintenance.
Extensions to the original response deadline have been discussed with Dave Verrelli and Floyd Cantrell by Jim Oomer of my staff.
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.
Vyry truly yours, TENNESSEE VALLEY AUTHORITY H.
G. Parris, Manager Power and Engineering (Nuclear)
C Enclosures
.cc:
Mr. James Taylor, Director (Enclosures)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 ag'OiQSO298 85 008Z59 pDR ADOCK 0>
pDR 8
An Equal Opportunity Employer
RESPONSE
NRC INSPECTION REPORT NOS.
50-259/85-45, 50<<260/85-45, AND 50<<296/85-45 ROGER D. WALKER'S LETTER TO H. G.
PARRIS DATED OCTOBER 28, 1985 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.
II This is a Severity Level IV violatiorr (Supplement I) and is applicable to all three units.
Contrary to the above, the licensee failed to maintain the Reactor Protection System (RPS) Circuitry as prescribed in drawing 791E247-2A Rev.
22.
On August 29,
- 1985, a terminal block jumper link which was required to be attached to terminals number 79 and 80 of terminal board CC on the Unit 1
RPS panel 9-17 was not attached with terminal screws.
This jumper link is in the RPS Scram Valve Test Timing"Marker Circuitry.
Additionally the fire proof metallic enclosures which house fuses F12, F13, F16 and F17 in panel 9-17 had lost their fire proof integrity due to the enclosure cover not being properly secured, leaving a one-half inch opening into the enclosure.
The wires required to be attached to terminal 3 of fuses F13 and F17 were not installed on the Unit 1 panel 9-17.
The one-half inch flex conduit from the fire proof metallic enclosures housing fuses
- F12, F13, F16 and F17 in panel 9-17 of Unit 1 was not terminated as close as possible to the terminal board but was terminated about one inch from the enclosure.
l.
Adm s D n a e
A ed
'o at o TVA admits the violation.
2.
a The discrepancies involved with the terminal block jumper link not being installed with screws, the fireproof metallic enclosure not being properly secured, and the wires not being attached to terminal 3
of the fuses in panel 9-17 of unit 1 appear to have been caused by a failure to strictly follow installation procedures during modifications to the panels.
Similarly, the flex conduit was not properly terminated because craftsmen used the adjacent wire way to route wires instead of using the flex conduit all the way to the terminal board during a modification.
Page 2
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The terminal block jumper link has been properly attached and the fireproof metallic enclosures have been properly closed.
An investigation was performed on the wires not being attached to terminal 3 of fuses F13 and F17 in panel 9-17 of unit 1.
The investigation showed the circuit was acceptable as installed; therefore, an as-constructed drawing discrepancy has been issued to correct the drawing.
The length of the one-half inch flex conduits to panels 9-17 and 9-15 on units 1 and 2 have been extended to as close as reasonable to the terminal block.
4.
Modifications has been made aware of this violation example so this will not occur during future modifications on the RPS pahels.
ak o A o'd 5.
C a c The remaining RPS panels will be inspected to verify all terminal block jumper links are properly installed, and all metallic enclosures are properly enclosed.
Personnel in eIectrical maintenance and electrical
'odifications will be instructed regarding proper installation practices particularly with regard to adherence to drawing details.
This item will also be discussed in detail in the monthly compliance bulletin which is distributed to all site sections for discussion.
Ac d
All inspections and personnel discussions will be completed by January 30, 1986.
Page 3
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Contrary. to. the. above,'-the licensee failed to"adhere to Standard Practice 17.9, Surveillance Requirements
- Program, on August 27, 1985 and August 28, 1985;.,Standard. Practice 17.9 requires that Surveillance-Instruction test data be maintained as quality assurance records with a lifetime retention period.
No Surveillance Instruction 4.9.A. 1.a, Diesel Generator Monthly Test, which was performed on Units 1 and 2 B Diesel Generator at 1430 on August 27,
- 1985, and again at 0105 on August 28, 1985 could be found.
1.
Admiss' or Den'al o he Al e ed o at on TVA admits the violation.
2.
asons or io ation Standard Practice 17.9 requires that all completed surveillance instructions be maintained as quality assurance records.
The standard practice was not, however, prescriptive with regard to documentation requirements for incomplete surveillance instruction data sheets.
We do agree that these data packages should have been. retained for record purposes and were erroneously discarded.
3.
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A'emorandum to all operations personnel has been issued to emphasize the procedures for handling test deficiencies and incomplete surveillance instructions.
An operations section instruction letter has been revised to provide more detailed guidance on handling of test deficiencies.
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A d
u Operator training will be administered to further stress the significance of the event.
BF 17.9 will also be clarified to accurately describe proper handling of 'surveillance packages.
This item will be discussed in detail in the monthly compliance bulletin which is distributed to all site sections.
5.
a e When u
Com
'ance W 'c ie ed Full compliance will be achieved by March 31, 1986.
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Page 4
/~aztec Contrary to the above, the licensee failed to adhere to Standard Practice 7.6, Maintenance Request and Tracking, on April 26, 1985.
Standard Practice 7.6 requires that Critical Structures Systems and Components (CSSC) and Safety Related Maintenance Requests (MRs) shall refer to Plant Operations Review Committee (PORC) reviewed instructions unless the maintenance to be performed involves skills normally possessed by qualified maintenance personnel and does not require step-by-step details for the actual performance of the work. If a PORC reviewed instruction is required and has not been written, an MR may be written and sent to PORC for review and the plant superintendent's approval.
On April 26, 1985, Maintenance Request A-170596 was performed on the safety-related TD2C relay with detailed step-by-step work instructions on the MR which had not been PORC reviewed and approved.
The work instructions involved operability verification of RHRSH pump autcmatic start logic circuitry which is normally verified during performance of approved surveillance instructions and is beyond the skills of qualified electrical maintenance personnel.
a o
TVA does not agree that this is an-example of the violation; however, the procedures which delineate when PORC review is required need additional clarification.
The intent of the administrative procedures is to base the content of written details required in an instruction on the skill of the craft and to base the decision for PORC review requirements-on the effect the work will"have on the performance of the equipment.
In this case, all work done with respect to the relay replacement and the subsequent return of the system to service was appropriately documented.
The relay had been installed with second-party verification for all wire connections, and the applicable section of the surveillance was reperformed.
The shift engineer requested additional testing even though second-party verification and performance of the surveillance could be accepted per our procedures.
The cognizant', electrical engineer then wrote the subject MR to functionally test the relay.
This MR was performed in accordance with applicable plant procedures.
Page 5
Q~ple~d Contrary to the above, plant-operating'instructions did not'address operation of the containment purge system. charcoal-bed heaters:.
On September 12, 1985, the charcoal,bed heaters were found with'he handswitch in the OFF position for all three units for no apparent reason.
The heaters remove any moisture accunulation which might reduce the required iodide removal capability of the charcoal bed as discussed in Technical Specification 3.7.F.2.6.
1.
d 's D
a ed V' o
TVA admits the violation.
2.
easo Fo io at o The. containment purge filter system is used to facilitate purging.of the drywell during normal shutdown operations and is not categorized as an engineered safeguards feature.
The system has a relatively minor safety function and both. the operating instructions and training program appear to have been suffering from a lack of emphasis.
We do,
- however, acknowledge that all operating instructions must be complet'e for all systems; and we have. embarked on a=-comprehensive program of operating instructions upgrade.
The same lack'f emphasis also was responsible for our failure to relate the earlier problem with the standby gas treatment system (reference:
Inspection Report 85-39) to this system.
3.
Correcti e S e Which Ha e B en Taken and su ts Ac eyed Operating Instruction 64, Primary Containment
- System, has been revised to include proper operation of the charcoal heaters.
4..
C ec te Wh'c W
ak n to A o d Fur e
V o at ons This system is included in the procedures upgrade list.
This item will be discussed in detail in the monthly compliance with emphasis placed on the need for consideration of potentially related problems during performance of failure evaluations.
5.
a e
u C
m
'ance Ac 'ed The event will be discussed in the December edition of the compliance bulletin.
-Page 6
10 CFR 50, Appendix B, Criterion VX requires that measures be established to control the issuance of documents, such as instructions, procedures and drawings, including changes
- thereto, which prescribe all activities affecting quality.
These measures shall assure that documents, including
- changes, are distributed to and used at the location where the prescribed activity is performed.
Contrary to the above, the licensee failed to issue and distribute as-constructed drawings documenting changes to the Vacuun Breaking System associated with the Condenser Circulating Mater System which occurred as a
result of work performed in July 197K, under work package number 5895 (Unit 1),
5991 (Unit 2)., and 7653 (Unit 3) for ECN Number L 2002.
Reference:
As-constructed Dwg. Number 47M831-3 Rev.
A.
This is a Severity Level IV violation (Supplement I) and is applicable to all three units.
l.
Adm s D
'a t
e ed o at TVA admits the violation.
2.
h a
The reason the drawings were not as-constructed cannot be determined from the available documentation.
After the modification was signed field complete, document control was to verify specified drawings associated with the workplan were as-constructed.
There was not a requirement to verify all drawings listed on the Engineering Change Notice (ECN) data sheet were as-constructed.
3.
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Ac Existing procedures for the closure of ECN and updating of drawing is considerably more rigorous than those which existed in l978.
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'on The vacua breaking systan drawings that were not as-constructed will be properly as-constructed.
5.
at e
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a c W'c ev d The drawings will be as-constructed by January 1, 1986.
EI
Page 7
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-Y 10 CFR 50, Appendix.B, Criterion XVI requires that measures shall be established to assure that conditions adverse to quality such as failures, malfunctions and 'deficiencies are-promptly identified and corrected.
- In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and cor rective action taken to preclude repetition.
Identification of the condition, cause of the condition, and corrective action shall be docunented and reported to appropriate levels of management.
The licensee failed to determine the cause and take corrective action to preclude repetition of a significant condition adverse to quality and further failed to document and report the cause and corrective action to appropriate levels of management.
On August 27,
- 1985, a significant condition adverse to quality occurred when the Units 1 and 2, B Diesel Generator failed to start when given an autanatic start signal during.the performance of a routine monthly surveillance test (SI 4.9.A.1.A, Diesel Generator Monthly Test).
Although various maintenance activities were performed over the next few days and the diesel subsequently passed the monthly surveillance on August 29, 1985, the cause of the original failure to start was not determined, documented or reported to management.
Since the cause was not determined, no action was taken to preclude repetition of the condition adverse to quality.
This is a Severity Level IV violation (Supplement I) and is applicable to all three units.
1.
dm ss o
o en a
eed a
TVA admits the violation.
2.
eas t
o a Maintenance personnel began work on the diesel generator immediately after it failed to start.
After maintenance was performed on several items that could have contributed to the failut e to start, the diesel generator performed as required.
Maintenance personnel believed the problem had been corrected by the activities even though the problem had not been positively identified.
Since a definitive reason for the failure was not established, no additional corrective action was initiated; and a specific report to management was not prepared.
The conclusion that the problem had been corrected appeared valid in that the diesel generator successfully passed its surveillance instruction three times. It is noted that a failure to start on this same diesel has recently occurred and is being investigated.
Page 8
3.
Corrective Ste s Which Have Been Taken and Results Achieved The diesel generator has been removed from service to complete scheduled vendor recommended maintenance.
During this maintenance, any components that could have resulted in this diesel generator's failure to start will be inspected.
The governor and turbo charger are being replaced.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations The removed governor will be sent to the vendor for inspection.
If the cause for the diesel generator's failure to start is not identified, steps will be taken to monitor the diesel generator when returned to service.
The procedure covering failure investigation requirements is considered adequate.
This event will be put in the compliance bulletin to be sure that those responsible for initiating comprehensive failure investigations are aware of the reason for this violation.
5.
Date When Full Co liance Will Be Achieved Maintenance on the diesel generator was completed on December 1, 1985.
ENCLOSURE 2
Please refer to your letter dated October 28, 1985, requesting a response to IE Inspection Report Nos. 50-259/85-45, 50-260/85-45, and 50-296/85-45 for our Browns Ferry Nuclear Plant which cited TVA with three Severity, Level IV violations.
The response to these violations is enclosed.
.Also, provided below is additional information on the three specific subjects mentioned in your cover letter.
Concerning the failure to perform vendor recommended diesel maintenance, an explanation of the circumstances associated with this condition is provided in the Licensee Event Report (LER) BFRO-50-259/85041 dated September 27, 1985.
Also, an internal safety evaluation discussing the effects of the missed preventive maintenance on diedel operability was prepared and reviewed by Plant Operations Review Committee.
A copy of the report was provided to the NRC resident inspectors.
A revision to the report is being prepared to address comments raised during the review by the TVA Nuclear Safety Review Board.
This revision will be sent to your office in the near future.
The diesel maintenance is proceeding and has been completed on one diesel.
The diesel vendor representative remarked on the overall good condition of the engine which he attributed to past care in operation of the diesel.
A second diesel is currently undergoing She inspection.
A detailed report will be provided to NRC following completion of the inspection on two of the unit 1/2 diesels and two of the unit 3 diesels.
This report will describe our observations and any noted problems.
With regard to the battery rack stud condition, a full explanation is provided in BFRO-50-259/85049 R1, dated November 15, 1985.
Shortly after the discovery of this condition, a worst case scenario was prepared assuming a catastrophic failure of the diesel batteries concurrent with a loss of offsite power.
This report is attached and shows that considerable time was available to take compensatory actions.
This report was also previously provided to the resident inspectors's noted in the LER, th-'" configuration was returned, to seismic acceptability on an expedited basis.
The relationship of violation l.d to a similar violation in Inspection Report 85-39 is discussed in the response to the subject violation.