ML18030B229
| ML18030B229 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/24/1986 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8604080325 | |
| Download: ML18030B229 (9) | |
Text
TENNESSEE VALLEY AUTHORITY 5N 105B Lookout Place
~'~> R ~I p p; g g March 24, 1986 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 PLANT UNITS 1, 2, AND 3 NRC-OIE REGION II INSPECTION REPORT 50-25 85-57 50-260/85-57, 50-296/85-57
RESPONSE
TO VIOLATIONS Enclosed is our response to J.
A. Olshinski's February 11, 1986 letter transmitting XE Inspection Report Nos. 50-259/85-57, 50-260/85-57, and 50-296/85-57 for our Browns Ferry Nuclear Plant which cited TVA with two Severity Level V Violations.
An extension of the response date was discussed between Floyd Cantrell of your staff and Mike Hellums of my staff on March 17, 1986.
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 J. A. Domer, Chief Nuclear Licensing, Enclosure cc:
Mr. James Taylor, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 8604080325 860324I PDR ADQCK 05000259 8
PDR An Equal Opportunity Employer
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RESPONSE
NRC INSPECTION REPORT NOS.
50-259/85-57, 50-260/85-57, AND 50-296/85-57 JOHN A. OLSHINSKI'S LETTER TO S.
A. MHITE DATED FEBRUARY 11, l986 10 CFR 50, Appendix B, Cr iterion II requires that the Quality Assurance Program shall be docunented by written policies, procedures or instructions and shall be car ried out in accordance with those policies, procedures. or instructions.
The Nuclear Quality Assurance Manual implements the licensee QA program.
Contrary to the above, the licensee failed to carry out the Quality Assurance Program in accordance with written policies, procedures, or instructions in the following examples:
a.
The Nuclear Quality Assurance Manual (NQAM) Part III, Section 7.1 requires that if defects, variations, deficiencies or deviations appear in an item to make it either unacceptable or of questionable quality, the item may not be used or installed until proper dispositions are obtained.
Itens which are unacceptable for use shall be identified, docunented, and segregated.
The iten shall be identified by use of a nonconforming iten (NCI) tag.
Six fuel channels which were found to be in nonconformance with the manufacturer's storage requirements on October 18, 1985, were not identified by use of, a nonconforming item tag.
The manufacturer required indoor storage; however,,the fuel channels (serial numbers
- B2296, B2145,
- B2223, B2253,
- B2239, and B2289) were stored outside with inadequate protection from the weather for about a year.
- b. 'he Nuclear Quality Assurance Manual (NQAM) Part II, Section 7. 1 contains the requirement for receipt inspection of fuel channels.
On November 19, 1985, Power Stores personnel receipt inspected six fuel channels (serial numbers
- B2296, B2145,
- B2223, B2253,
- B2239, and B2289) which were returned from the Mechanical Maintenance Section.
This receipt inspection failed to adhere to the NQAM requirements as follows:
(1) Inspection personnel were not certified fuel receipt inspectors.
(2) The inspection was not docunented on Attachment 4, the Fuel and Component Receipt Inspection Master Checkoff Log.
(3) Excessive chloride (1010 ug/dm2) contamination found on Channel number 2239 was not docunented on the Site Fuel Discrepancy Report.
(4) Resolution of the excessive chloride contamination found on Channel 2239 was not reviewed and approved by the Site Reactor Engineer, Chief Reactor Engineering Branch, Plant Operations Review Committee, and the Plant Superintendent.
Page 2
Item 1 continued This is a Severity Level IV Violation (Supplement
- 1) and is applicable to all three units.
l.
Admission or Denial of the Alle ed Violation TVA admits the violation.
2.
Reasons for the Violation The subject channels were removed from stores in late 1984.
The requirement to maintain indoor storage was not. subsequently recognized and the crated channels were stored outside the reactor building near the equipment access hatch for later use.
When the channels were found
- outside, they were transported to the refueling floor for unpacking and inspection before being, returned to power stores.
Mechanical maintenance requested
- that, a visual inspection and cleaning be performed on the six channels as described in GOI 100-2.
This operation was done by certified fuel receipt inspectors and documented in refuel floor assistant unit operator log dated October 23, 1985.
Mechanical maintenance also requested chloride smears to be performed by chemical engineering.
The standard inspection procedure (GOI 100-2) does not require chloride smears.
However, since the storage requirements had not been maintained, it. was prudent to check the channels and clean as necessary before turning the items to the parts inventory.
One test smear on a single channel was higher (value
= 1.01 mg/100 cm ) than the standard for allowable tramp surface contamination.
The channel was cleaned and rechecked satisfactorily on October 30, 1985.
Power stores subsequently inspected'the channels on November 19, 1985, and the channels were accepted into the inventory.
In regards to identifying items as ~~>
nonconformance items, mechanical maintenance personnel were not familiar with nonconforming procedures which led to the channels not being nonconformed immediately after initial discovery of the storage problem.
Part B of the violation refers to failure to adhere to the NIZAM requirements for fuel-related components.
The formal inspection referred to in the N(}AM is GOI 100-2, which was partially performed on the six channels as discussed in part A.
This GOI 100-2 inspection is normally performed on this equipment before being placed in service and these six channels will undergo the complete inspection before use.
Due to the incorrect, storage controls in part A, the partial inspection was performed, but was never intended to meet the. formal GOI 100-2 inspection.
The inspections performed were to allow the channels to be returned to storeroom inventory only.
Page 3
Corrective Ste s Which Have Been Taken and Results Achieved As described in item 2, the channels have been inspected,
- cleaned, and returned to stores.
Corretive Ste~s Which Mill Be Taken to Avoid Further Violations This violation will be discussed at the maintenance foreman's meetings.
The two errors made in part a. of the violation will be highlighted.
The six channels will receive the GOX 100-2 preservice inspection before being put into service in accordance with normal fuel handling activities.
Date Mhen Full Com liance 'Will Be Achieved The corrective actions discussed in item 4 will be completed by April 18, 1986.
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Page 4
Technical Specification 6.3.A.6 requires that detailed written procedures shall be prepared, approved and adhered to. for surveillance and testing requirements.
Contrary to the above, this requirement was not met in that sixteen surveillance instructions required by technical specifications were not performed in the required time interval.
The licensee reported these omissions in Licensee Event Report 259/85-50 dated November 1, l985.
The surveillances were inadequately scheduled for the plant condition of shutdown and refueling.
Surveillance Instruction, SI-1, Surveillance
- Program, used by plant personnel to schedule surveillances c'ontained errors and was generally not in accordance with technical specifications.
This is a Severity Level IV Violation (Supplement I) and is applicable to all three units.
l.
~d~s:~o ~ ~n~a of ~t
)~Igdd boa~on TVA admits the violation.
We point out that this is a licensee identified iten.
2.
~canon
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~tt gjg~atjon A management review of surveillance scheduling completed on October 3, 1985, discovered that several instrument surveillances were not being performed in strict accordance with technical specification (TS) surveillance requirements when a unit is shut down for refueling.
TS 3.2.B requires this instrumentation be tested whenever the systen is required by section 3.5 of TS.
A conservative interpretation of section 3.5 provisions would require all automatic functions serving the emergency core cooling systems be available in shutdown mode.
Also, scram discharge valve testing required by TS 3.3.F, Scr am Discharge Volume (AA), and 3.7.H, Containment Atmosphere Monitoring System H Analyzer (IK) were also not required by the surveillance scheduling instruction (Surveillance Instruction [SII-1) Appendix C
when shutdown.
Subsequently, a review of the schedule during the current outage situation indicated several of these SIs had not been performed on each unit.
Licensee Event Report BFRO-50-259/85050 lists the specific surveillances that were not performed.
The root cause of this problem was the failure to fully implement TS requirements in plant procedures and personnel error in TS interpretation.
In preparing the surveillance
- schedule, applicability of the SIs were determined by a logical need for the SI based on plant conditions rather than the literal meaning of TS.
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Page 5
All of the SIs not performed on units 1 and 3 were subsequently performed with the exception of SI 4.2.B.69 (Recirculation Pump Trip Reactor High Pressure) on unit 1.
This was not performed because the recirculation pumps (AD) were not operating, and the reactor head had been removed.
Unit 2 SIs were not performed because the fuel had been
- unloaded, and the applicable systens were no longer required by TS.
Subsequent performance of each surveillance indicated that the operability of the instruments was not affected.
The setpoints of the various instruments are based on design basis type events and substantial drifts would be necessary to adversely affect any events
'that could originate from cold shutdown conditions.
Appendix C to SI-1 was revised on November 6, 1985, to accurately reflect the requirements for performance of these surveillances during refueling.
The restart activities for unit 2 include a general review of surveillance instructions.
SI-1 will be cocurrently reviewed to ensure the accurate translation of technical specifications into surveillance scheduling requirements.
The actions described in step 4 will be completed prior to unit 2 startup.