ML18031B110
| ML18031B110 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/29/1986 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF ADMINISTRATION (ADM), Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8701050144 | |
| Download: ML18031B110 (9) | |
Text
TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 5N 157B Lookout Place DEC 20 588 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Office of Nuclear Reactor Regulation Washington, D.C.
20555 Attention:
Dr. J. Nelson Grace In the Matter of the Tennessee Valley Authority Docket Nos.
50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 NRC-OIE REGION II INSPECTION REPORT 50-259/86-32, 50-260/86-32, AND 5 -2 86-32
RESPONSE
TO VIOLATION and 50 296/86 32 for our Browns Ferry Nuclear Plant which cited Severity Level V violations'f you have any questions, please get in touch with M. J.
May at (205) 729-3566.
Enclosed is our response to G.
G. Zech's December 4,
1986 letter to S.
A. White transmitting IE Inspection Report Nos. 50-259/86-32, 50-260/86-32, TVA with two To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY y A.
J.
A. Domer, Assistant Director Nuclear Safety and Licensing Enclosure cc:
See page 2
a
~DO'CI'I e 87P1 pgp) t g
OCR pg000 PDR g,aI-An Equal Opportunity Employer
l
~
h
U.S. Nuclear Regulatory Commission OEC 2O ee cc (Enclosure):
U.S. Nuclear Regulatory Commission Region II Attn:
Dr. J.
Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. James M. Taylor, Director U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Washington, D.C.
Mr. G.
G. Zech, Director U.S. Nuclear Regulatory Commission TVA Projects 101 Marietta Street, NW, Suite 2900 Atlanta Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant P.O.
Box 2000
- Decatur, Alabama 35602
RESPONSE
NRC INSPECTION REPORT NOS.
50-259/86-32, 50-260/86-32, AND 50-296/86-32 G.
G.
ZECH'S LETTER TO S.
A. MHITE DATED DECEMBER 4, 1986 Item A Technical Specification 6.3.A requires that detailed written procedures covering surveillance requirements shall be prepared, approved and adhered to.,
Surveillance Requirement 4.6.E.2.a requires in part that the Control Room Emergency Ventilation System flow rate shall be shown to be within + 10%
design flow when tested in accordance with ANSI N510-1975 at the specified intervals.
ANSI N510-1975 requires that a Pitot-tribe velocity-traverse be made in accordance with Section 9 of American Conference of Government Industrial Hygienists (ACGIH) "Industrial Ventilation" manual at a point in the duct where airflow velocity is 1,000 fpm or more. If there is no place where the airflow is greater than 1,000 fpm, use one of the other methods as described in Section 9 of the ACGIH "Industrial Ventilation" manual.
Contrary to the above, Surveillance Instruction 4.7.E.5, Control Room Emergency Ventilation System Flow Rate Test, does not adequately satisfy the requirements in that a Pitot-tube velocity-traverse is specified as an acceptable method of flow rate testing even though there is no place in the duct where the airflow is greater than 1,000 fpm.
This is a Severity Level V Violation (Supplement I) and is applicable to all units.
1.
Admission or Denial of the Alle ed Violation TVA admits the violation as stated.
2.
Reasons for the Violation The Surveillance Instruction (SI) allowed the Control Room Emergency Ventilation System (CREVS) flow rate to be determined by utilizing any one of three specified flow measuring devices.
The pitot-tube was one of those specified and no minimum flow rate or special measuring devices were listed as required with its usage.
The expected Control Room Emergency Ventilation System flow was approximately 750 feet per minute (fpm).
ANSI N510-1975 requires that for airflows less than 1000 fpm, other methods as described in Section 9 of ACGIH Industrial Ventilation should be utilized in place of the standard pitot-tube velocity-traverse.
Therefore, a lack of procedural detail concerning the usage of the pitot-tube was the reason for the violation.
t,
3.
Corrective Ste s Which Have Been Taken and Results Achieved As described in Section 9 of ACGIH, the accuracy of the pitot is limited at velocities below 1000 fpm because the standard manometer is not precise enough to accurately measure small pressures.
TVA's alternate method will be to utilize the pitot in conjunction with a highly accurate manometer
(+.001 inches of water column) when performing the pitot-tube velocity-traverses.
This combination of equipment is recognized by ACGIH for velocities below 1000 fpm.
Surveillance Instruction 4.7.E.5 has been revised to specify use of this equipment which satisfies the ANSI N510-1975 requirements.
The test method previously utilized involved pitot-tube velocity-traverses with a 10 to 1 inclined manometer as the readout. device, accuracy
.0025 inches of water column, Although the procedure was not in compliance with ANSI N510-1975 requirements, technically adequate test results were obtained.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations Other systems tested in accordance with ANSI N510-1975 were reviewed to see if the minimum velocity requirement was met.
All systems tested in accordance with ANSI N510-1975, as required by Technical Specifications, meet the minimum velocit re uirement.
t y
5.
Date When Full Com liance Will Be Achieved All corrective actions for units 1, 2, and 3 are complete.
Item B
10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be accomplished in accordance with prescribed instructions, procedures, or drawings.
Browns Ferry Standard Practice, BF 10.9, Handling of Test Deficiencies, which implements the Nuclear Quality Assurance Manual, Part II, Section 4.9, requires equipment deficiencies during a test or surveillance instruction be documented and included along with the final disposition as part of the documentation package for the test being performed.
Contrary to the above, this requirement was not met because equipment malfunctions observed during the performance of Surveillance Instruction (SI) 4.5.C.1 (4), Emergency Equipment Cooling Water (EECW) Annual Flow-rate Test, on August 22,
- 1986, were not identified or documented as part of the completed documentation package.
During the SI the EECW cross-connect (67-50) did not open as expected.
The Uni;t 1 valve did not open.
The Unit 2 valve only opened to an intermediate position.
Flow through these valves was considered part of the normally assigned flow path of Technical Specification surveillance requirement 4.5.C.1.6.
The SI was repeated on September 2,
1986.
The Unit 1 valve was found out of adjustment, as documented on Maintenance Request (MR) 755513.
The Unit 2 valve had a stuck solenoid in the control circuit for the valve, as documented on MR 753912.
Final Safety 'Analysis Report Section 10.10.3, states these valves are designed to open upon loss of raw cooling water pressure and close on low header pressure to guarantee flow to the emergency equipment components.
This is a Severity Level V Violation (Supplement I) and is applicable to all three units.
l.
Admission or Denial of the Alle ed Violation or Findin TVA admits the violation as stated.
2.
Reasons For the Violations or Findin if Admitted Definitive evaluation of the operation of 1/2-FCV-67-50 on August 22, '1986 was obscured when Surveillance Instruction 4.9.A.l was initiated from the unit 1/2 Control Rooms.
Surveillance Instruction 4.9.A.1 starts additional Emergency Equipment Cooling Water pumps, an inappropriate condition for continuing Surveillance Instruction 4.5.C.1(4).
Although the unit 3 Control Room Operator did not have clear indication of valve malfunction, he should have noted the potential discrepancy in valve operation when his activity was interrupted.
3.
Corrective Ste s Which Have Been Taken and Results Achieved Operations personnel have been counseled in the provisions of BF 10.9, Handling of Test Deficiencies, emphasizing the need to annotate perceived discrepancies while conducting surve'illance testing.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations or Findin s Operations personnel will be retrained in <he requirements of BF 10.9, Handling of Test Deficiencies'.
Date When Full Com liance Will Be Achieved Operations personnel retraining will be completed by March 31, 1987.