ML18030B320

Responds to NRC 860401 Ltr Re Violations Noted in Insp Repts 50-259/86-06,50-260/86-06 & 50-296/86-06.Corrective Actions: sign-off Form & SI 4.11.A.1-e of Surveillance Instruction Revised.Critiques Describing SI 4.8B2-3A Given to Staff

ML18030B320
Person / Time
Site:	Browns Ferry
Issue date:	05/01/1986
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8605200256
Download: ML18030B320 (19)

Text

TENNESSEE VALLEY AUTHORITY CHATTANOOGA, TENNESSEE 37401 5N 157B Lookout Place LJ

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May 1, 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 NUCLEAR PLANT UNITS 1, 2, AND 3 NRC-OIE REGION II INSPECTION REPORT 50-259/86-06, 50-260/86-06, 50-296/86-0 RESPONSE TO VIOLATIONS Enclosed is our response to J. A. Olshinski's April 1, 1986 letter to S. A. White transmitting IE Inspection Report Nos. 50-259/86-06, 50-260/86-06, and 50-296/86-06 for our Browns Ferry Nuclear Plant which cited TVA with two Severity Level IV Violations.

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. L. Gridley, irector Nuclear Safety and Licensing Enclosure cc: Mr. James Taylor, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 8605200256 860501 PDR ADOCK 05000259 8

An Equal Opportunity Employer

C

RESPONSE

NRC INSPECTION REPORT NOS.

50-259/86-06, 50-260/86-06, AND 50-296/86-06 JOHN A. OLSHINSKI'S LETTER TO S. A. WHITE DATED APRIL 1, 1986 Item 1

1. Technical Specification 6.3 requires that detailed written procedures, including applicable checkoff lists, for surveillance and testing requirements shall be prepared, approved and adhered to; and temporary changes to a procedure" may be made which do not, change the intent of the approved procedure.

Contrary to the above, this requirement was not met for the following examples:

a. Surveillance Instruction SI-4.11.A.l-e, Testing of Fixed Water Nozzles for Blockage, performed February 5-10, 1986, was inadequate in that, a non-intent change processed on January 29, 1986, incorrectly deleted one of two isolation valves for fire protection nozzle zones A through F and remained undetected during testing on Units 1 and 2 until another non-intent change was processed on February 5, 1986, correcting the procedure for the missing isolation valves for unit 3. Additionally, the procedure data sheet format inadequately contained overlapping signature blocks and column headings such that during the test, signatures were being made for the test connection installation and removal only'and not for the nozzle inspection as required.

b. Temporary changes, termed non-intent changes, were made to SI 4.11.A.l-e which were intent changes. Browns Ferry Standard Practice 1.3 defines intent changes as changes in scope, technique, or sequential order of instruction steps that would affect the result of nuclear safety. A non-intent change processed January 29, 1986, changed 38 valves to the procedure changing a majority of the steps in the procedure. The changes to the isolation valves affected the number of fire protection zones removed from service at one time.

Although the fire protection engineer reviewed the original procedure, the non-intent, change which affected the fire protection system was not reviewed prior to implementing the change.

Ce During performance of SI 4.8.B.2-3A, Airborne Effluents (Weekly Gamma Isotopic), on February 5, 1986, Procedure Step VI B.l of Chemistry Instruction CI 701 was not performed to verify the keyboard terminal in use was connected to the counter containing the sample. A sample of free air was being counted until this error was detected by another person not. performing the test.

d. SI 4.8.B.2-3A, Airborne Effluents (Weekly Gamma Isotopic), performed on February 5, 1986, which referenced Chemistry Instruction 466.5 (Stack Monitor Sampling) was inadequate in that it did not contain a

previously issued non-intent change dated Novembex 1985. The procedure, if performed as written, left the continuous monitor inoperable after the sample was taken due to the closing of two system valves (AO-305A and A0-282N).

e. Surveillance Instruction SI 4.4.C.3, Standby Liquid Control System-Boron Concentration, was .not adhered to on February 10, 1986.

SI 4.4.C.3 requires that the Standby Liquid Control System (SLC) be sampled per Chemistx'y Instruction CI 463.1. Step VI.C of CI 463.1 requires that valve 2-63-536 be locked closed and verified locked closed. While sampling the unit, 2 SLC System on February 10, 1986, enclosed both the valve operator and the chemistry technician initialed the Data Sheet for SI 4.4.C.3 indicating that valve 2-63-536 was locked and second person verified locked closed even though no locking device was attached to the valve.

f. Standard Practice 14.25, Clearance Pxoceduxe, Step 6.4.4. requix'es that the appx'opx'iate protective tags must be propexly applied in all instances. Contraxy to this, the following clearance tags were not appropriately applied:

(1) On February 9, 1986, tags 4, 5, and 7 of clearance No. 85-1304 were not attached to a lifted lead of the shorting link of fuse block FB1 on unit 2 panels 9-83, 9-84, and 9-86, respectively.

(2) On February 12, 1986, tag=No. 12 of clearance 'No.85-949 was iiot attached to a dowel pin which should have been installed in place of removed fuse 13A-F23 on the unit 2 panel 9-33.

(3) On February 12, 1986, tag No. 8 of clearance No. 85-1517 and tag No. 6 of clearance No.85-949 were not attached to a dowel pin which should have been installed in place of removed fuse 10A-FlA on the unit 2 panel 9-32.

(4) On Februaxy 17, 1986, tag No. 11 of cleax'ance No.85-510 was found attached to the Limitorque valve operator for valve 2-FCV-74-77.

The valve had been disassembled and removed from the system even though the protective tag was attached to the valve operator establishing the valve as a clearance boundary for unrelated maintenance.

This is a Severity Level IV violation (Supplement I) and is applicable to all units.

Item 1a.

1. Admission or Denial of the Alle ed Violation TVA admits the violati'on.

2. Reasons for the Violation The omission of the isolati:on valves was an oversight at the time the non-intent change was written. Closing the additional isolation valve provides an additional safety precaution in case the associated deluge valves were accidently actuated during the performance of the test. The test involves only the dry portion of the fire protection system. In regard to the overlapping signature blocks, the form can be misleading although the nozzle inspection was performed and is evidenced by the initials of the inspector.

3. Corrective Ste s Which Have Been Taken and Results Achieved As the violation stated, the procedural omission was corrected. The sign-off Eorm in the Surveillance Instruction is in the process of revision to preclude any misinterpretation of signature blocks that verify inspections or installations. The Surveillance Instruction is being permanently revised to include all isolation valves. Also, all fire protection procedures are now the responsibility of the fire protection engineer. This will consolidate the responsibility for the accuracy of the procedures.

4. Corrective Ste s Which Will Be Taken to Avoid Further Violations The steps discussed in step 3 should prevent further violations. Also, an additional engineer reporting to the fire protection engineer will be assigned the initial responsibility for upgrading and maintaining, the procedure to ensure that it is correct and that it complies with the instruction preparation guidelines.

5. Date When Full Com liance Will Be Achieved The procedure revisions delineated in step 3 will be approved by May 15, 1986.

Item lb.

1. Admission or Denial of the Alle ed Violation TVA admits the violati'on.

2. Reasons for the Violation Surveillance Instruction SI 4.11.A.l-e incorrectly showed the deluge valves as the isolation valves. The non-intent change performed on January 29, 1986 was generated to correct the procedure. We agree that the change was incorrectly categorized as non-intent in that the scope of the instruction was expanded in the number of Eire protection zones affected.

We point out that Standard Practice BF-14.15, "Removal of Fire Protection Equipment From Service," Form BF=31, is used for controlling removal of fire protection equipment from service. The Form BF-31 identified the correct isolation valves for isolating the system to perform the Surveillance Instruction. Therefore, the zones removed from service did not actually change when the non-intent change was written. This may have affected the original determination as to the categorization of this change as non-intent.

3. Corrective Ste s Which Have Been Taken and Results Achieved The permanent revision in process has been reviewed and determined to be correct by the fire protection engineer.

4. Corrective Ste s Which Will Be Taken to Avoid Further Violations r'nder normal circumstances, the individual who made the non-intent change would be counseled regarding the requirements Eor temporary procedure changes. However, the responsible individual is no longer employed by TVA, and we believe this issue is an isolated case.

5. Date When Full Com liance Will Be Achieved The permanent revision discussed in step 3 will be issued by May 15, 1986.

Item 1c.

l. Admission or Denial of the Alle ed Violation TVA admits the violation.

2. Reasons for the Violation The technician did not correctly follow the procedure for checking for the proper terminal connection. The count room equipment, configuration had been changed and the individual assumed from past, experience that the correct. terminal was being used 'for the counter.

3. Corrective Ste s Which Have Been Taken and Results Achieved The condition was recognized and corrected before completing the test. The individual was issued a written warning for failure to strictly follow procedure requirements. This incident was investigated and discussed with laboratory personnel during a chemistry section meeting on February 6, 1986.

4. Corrective Ste s Which Will Be Taken to Avoid Further Violations Subsequent recurrences by the same individual will result in a higher degree of disciplinary action. A critique is being written on the incident, which will be distributed to all chemistry section personnel by May 15, 1986. This critique will-focus on the need for procedural adherence.

5. Date When Full Co lienee Will Be Achieved Full compliance has been achieved with the exception of the critique which is to be completed by May 15, 1986.

l. Admission or Denial of the Alle ed Violation TVA admits the violation.

2. Reasons for the Violation The laboratory analyst used an incomplete working copy of the procedure and failed to check it against the controlled copy. Therefore, it did not contain the non-intent change.

3. Corrective Ste s Which Have Been Taken and Results Achieved The individual was given a verbal warning. The incident was thoroughly investigated and discussed at a chemistry section meeting on February 6, 1986. Laboratory personnel were-instructed to verify the latest revision of each procedure..is utilized for all activities.

4. Corrective Ste s Which Will Be Taken to Avoid Further Violations Subsequent recurrences by the same individual will result in a higher degree of disciplinary action. A critique i;s being written on the incident, which will be distributed to all chemistry section personnel by May 15, 1986. This critique will focus on the use of current procedures.

5. Date When Full Co liance Mill Be'Achieved Full compliance has been achieved with the exception of the critique which is to be distributed by May 15, 1986.

P Item le.

l. Admission or Denial of the Alle ed Violation TVA admits the violation.

2. Reasons for the Violation The assistant operator closed and locked valve 2-33-756 and closed but failed to lock the valve 2-63-536. The chemistry technician was convinced by the operator that an air isolation valve upstream of valve 2-63-536 was locked closed, therefore, no locking device was needed for valve 2-63-536. Both parties failed to strictly follow procedures.

3. Corrective Ste s Which Have Been Taken and Results Achieved The valve lock was promptly installed upon notification of the problem to the assistant shift engineer. Both the chemistry technician and valve operator have been counseled and have received a verbal reprimand. The point was emphatically stressed that they will comply with procedure requirements, and their signature must represent actual physical verification as required by procedure.

4. Corrective'te s Which Have Been Taken to Avoid Further Violation In order that management further stress the importance of adherence to plant instructions at all times, a critique involving this incident was written, No. 86-0003, which detailed the valve operator and chemistry technician's error. The critique was required reading for all chemistry and operations personnel and was titled, "Failure to Adhere to Plant Instructions." The critique has been distributed.

5. Date When Full Com lienee Will Be Achieved Full compliance has been achieved.

Item lf.

1. Admission or Denial of the Alle ed Violation TVA admits the violation.

2. Reasons for the Violation There is an apparent lack of awareness by several personnel concerning the importance of clearance procedure adherence and the associated precautions which must be followed.

3. Corrective Ste s Which Have Been Taken and Results Achieved All protective tags have been properrly applied and the valve, 2-FCV-74-77, is part of the head spray system which has been permanently removed from service.

4. Corrective Ste s Which Will Be Taken to Avoid Further Violation A site-wide familiarization course will be implemented by the end of May 1986 on the requi,rements of the clearance procedure. Until site personnel will perform checks in the plant on weekends for that the time, purpose of providing the coverage we believe is necessary to avoid further clearance tag deficiencies.

5. Date When Full Co liance Will Be"'Achieved The corrective actions discussed in item 4 will be implemented by May 31, 1986.

Item 2 Technical Specification 3.5.C.7 requires that, there shall be at least two RHRSM pumps, associated with the selected RHR pumps, aligned for RHR heat exchanger service for each reactor vessel containing irradiated fuel.

Contrary to the above, the requirement was not met on January 25, 1986, when no RHRSW pump, associated with one of the selected RHR pumps, was operable for RHR heat exchanger service. While the reactor vessel contained irradiated fuel, loop II RHR pumps 3B and 3D were taken out of service. This left loop I RHR pumps 3A and 3C as the selected RHR pumps. RHRSM pumps A1 and A2 are the only pumps that can be associated with RHR pump 3A. These pumps became inoperable when their emergency diesel generator was taken out of service for maintenance at 5:50 a.m. on January 25, 1986. The condition existed for about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> until the emergency diesel generator was returned to service.

This is a Severity Level IV violation (Supplement I) applicable to unit 3 only.

1. Admission or Denial of the Alle ed Violation TVA admits the violation.

2. Reasons for the Violation The cause of the event is not, a misinterpretation of Technical Specification 1.C.2, and therefore, we do not believe this is similar to violation 259, 260/84-26-02. The"shift personnel did declare RHRSM pumps Al and A2 inoperable in accordance with Technical Specification 1.E.

Their error arose when they failed to realize that, because of the surveillance in progress, loop II was considered inoperable. Thus, Technical Specification.3.5.C.7 was not satisfied for approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, since RHR pump 3A did not have a ~orresponding RHRSW pump fully operable due to the diesel generator being, out of service. The interrelated Technical Specification is 3.S.B.9 which states, "When the reactor vessel pressure is atmospheric and irradiated fuel is in the reactor vessel, at least one RHR loop with two pumps or two loops with one pump per loop shall be operable. The pumps associated diesel generators must also be operable.'"'he shift personnel were not aware that loop II was inoperable due to the scheduled surveillance test and considered loop II the "selected" RHR pumps, and therefore, 3.5.C.7 satisfied.

3. Corrective Ste s Which Have Been Taken and Results Achieved The diesel generator had been returned to service at 1817 on January 25, 1986, resulting in about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of inoperability.

4. Corrective Ste s Which Have Been Taken to Avoid Further Violation Standard Practice BF-12.24, "Conduct of Operations" was issued in February 1986. The document requires that the shift engineer complete

a turnover checklist each shift. This checklist includes listing surveillances in progress, surveillances completed, and safety-related

" equipment.out-of-service. This will ensure that, shift personnel are aware of plant status. In addition, our review of this event identified the fact that in certain cases technical specification operability is more restrictive during cold shutdown than during plant operation. We are evaluating this issue for possible relaxation of component operability during cold shutdown.

5. Date When Full Co lienee Will Be Achieved Standard practice BF-12.24 has been fully implemented.

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