ML18033A823

Responds to NRC 890508 Ltr Re Violations Noted in Insp Repts 50-259/89-06,50-260/89-06 & 50-296/89-06.Corrective Actions: Surveillance Instruction Revised to Inform Operator of Pending Half Scrams & Steps for Clearing Half Scrams

ML18033A823
Person / Time
Site:	Browns Ferry
Issue date:	07/07/1989
From:	Michael Ray TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8907120172
Download: ML18033A823 (27)

Text

.gC CE1ZRATED D1STKBU'EON DEMONSTRA,TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) 'I CCESSION NBR:8907120172 'OC.DATE: 89/07/07 NOTARIZED: NO DOCKET FACIL:50-259,Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Stat'ion, Unit 3, Tennessee 05000296 AUTH. NAME .AUTHOR AFFILIATION RAY,M.J. --.. Tennessee Valley Authority .,

RECIP.NAME (" RECIPIENT AFFILIATION..

Document'Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 890508 ltr re violations noted in Insp Repts 50-259/89-06,50-260/89-06 6 50-296/89-06.

DISTRIBUTION CODE: IE01D TITLE: General,"(50 Dkt)-Insp

'I' COPIES RECEIVED:LTR R5'pt/Notice

+ ENCL SIZE:

of Vio ation'Reiponse'-.':

~

NOTES: 1 Copy each to: B.Wilson, D.M.Crutchfield,B.D.Liaw,S.Black 05000259 R.Pierson, A.

1 Copy each to: S.Black,D.M.Crutchfield,B.D.Liaw, 05000260 R.Pierson,B.Wilson D 1 Copy each to: S. Black,D.M.Crutchfield,B.D.Liaw, 05000296 R.Pierson,B.Wilson D RECIPIENT COPIES RECIPIENT COPIES PD ID CODE/NAME "

1,1 LTTR ENCL ID

'GEARS,G CODE/NAME ,

LTTR' ENCL 1

NTERNAL: ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1 AEOD/TPAD 1 1 DEDRO 1 1 NRR SHANKMAN,S 1 1 1

.NRR/DEST DIR NRR/DOEA DIR NRR/DREP/RPB 10 ll 1 1

2 1

1 2

NRR/DLPQ/PEB NRR/DREP/EPB 10 NRR/PMAS/ILRB12 1

1 1

1 1

NUDOCS-ABSTRACT 1 1 OE LIEBERHAN J 1 1 OGC/HDS2 1

~IL'E. 1: .

'1 RES MORISSEAU g D 1 1 G~ FILE Ol 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOTES 5 5 D

NCIE 'IO ALL 'KIDS" RECIPIIMSo S

EKEASE HEXiP US IO REIXKH %QHR! CXNZhCT 'IHE DOQ3MEPZ CGHZRDL DESK, LISTS KR DOCXHEMIS VXJ DCSERT NEZDf TOTAL NUMBER OF COPIES REQUIRED: LTTR 30 ENCL ,30

~ r

i~

TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 5H 157B Lookout Place JUL (

39B('.S.

Huclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Hatter of Docket Hos. 50-259 Tennessee Valley Authority 50-260 50-296 BROOMS FERRY NUCLEAR PLA'NT UNITS 1, 2, AHD 3 HRC INSPECTION REPORT NOS.

50-259/89-06, 50-260/89-06, AHD 50-296/89-06 RESPONSE TO NOTICE OF VIOLATION This letter provides TVA's response to the notices of violation and deviation transmitted by letter from B. A. Milson to O. D. Kingsley, Jr. dated May 8, 1989. The report cited TVA with two violations. The first violation had two examples describing multiple examples for failure to comply with procedures and inadequate procedures. The second violation noted a failure to maintain quality assurance records., TVA admits both violations. A deviation was also identified in that. TVA failed to conduct. an adequate review of Surveillance Instructions (SIs). This review had been committed to in TVA's Nuclear Perfonnance Plan (HPP) Volume 3, Revision l.

TVA notes that the problems identified did not adversely affect the operability or calibration of the instruments. Because of NRC concerns, TVA management has initiated activities aimed at improving the existing SI program as follows:

1. TVA established an SI task force to review and to make recommendations in the following areas: Training on the conduct. of testing, procedure reviews, scheduling, and personnel accountability. BFH is completing corrective actions to correct, identified deficiencies. In addition, conduct of testing training is being completed by personnel who perform SIs ~

2. BFH has revised SDSP 7.4, "Procedure Review," to: (1) Establish a formal process to validate the SIs and other man-machine interface procedures, (2) incorporate HUREG/CR-1369, "Procedures Evaluation Checklist for Haintenance, Test and Calibration Procedures Used in Nuclear Power Plants," Revision 1, and IHPO 84-020 (Good Practice OP-210) criteria, (3) provide qualifications for qualified reviewers and validators, (4) combine several checklists into one comprehensive checklist to minimize procedural deficiencies, and (5) consolidate SI verification and validation requirements into one procedure.

8907120172 8ci0707 PDR ADOCK 05000259 0 PDC An Equal Opportunity Employer

U.S. Nuclear Regulatory Commission JUL 7 195

3. BFN has provided training to Operations and Instrumentation and Control personnel to prevent the reoccurrence of the noted adverse activities.

These activities and increased management attention in -this area ensure that TVA complies with the intent of the commitments described in HPP Volume 3, Revision 1..

Additionally, TVA notes that the oral commitments enclosed in the inspection report are documented correctly as requested by HRC. provides TVA's response to the two violations in the subject report. Enclosure 2 provides TVA's response'to the deviation from a commitment made in TVA HPP Volume 3, Revision 1. A list of commitments is provided in enclosure 3.

Milliam Little of your staff agreed to an ext,ension of the due date of this response to July .7, 1989.

If you have any questions, please telephone Patrick P. Carier, BFN, at (205) 729-3570.

Very truly yours, TENNESSEE VALLEY AUTHORITY i7;:.,

Hanager, Nuclear Licensing and Regulatory Affairs Enclosures cc (Enclosures):

Hs. S. C. Black, Assistant Director for Projects TVA Projects Division U.S.'uclear Regulatory Commission One Mhite Flint, North 11555 Rockville Pike Rockville, Haryland 20852 Hr. B. A. Wilson, Assistant Director for Inspection Programs TVA Projects Division U.S. Hucleax. Regulatory Commission Region II 101 Harietta Street, HM, Suite 2900 Atlanta, Georgia 30323 HRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000

0 ENCLOSURE 1 RESPOHSE TO VIOLATIONS HRC IHSPECTIOH REPORT HOS. 50-259/89-06, 50-260/89-06, AHD 50-296/89-06 LETTER FROM B. A. MILSOH TO 0. D. KIHGSLEY, JR.

DATED HAY 8, 1989 A. Technical Specification (TS) Section 6.8.1.1.c., requires that written procedures shall be established, implemented and maintained covering surveillance and test activities for safety-related equipment.

Site Director's Standard Practice (SDSP) 2.1, "Site Procedures and Instructions," requires that the site shall be operated and maintained in accordance with written. approved procedures and instructions which have been formally issued and distributed for use. SDSP 2.1 also states that personnel shall not give directions, guidance, recommendations or clarification- which conflict 'with approved procedures.

1. Contrary to the above, during the performance of SIs and instrument calibrations, procedures were not properly implemented in the following events.

V Admission or Denial of the Alle ed Violation TVA admits each event of this violation and will address the reason for the violation (or finding) if admitted, the corrective actions which has been taken and the results achieved, the corrective action which will be taken to avoid further violations (or findings) and the date when full compliance will be achieved'.

On January 30, 1989, surveillance procedure 2-SI-4.1B-6(A),

"Reactor Prot. ection and Primary Containment Isolation Systems Low Mater Level Instrument Channel Al Calibration," was not properly implemented in that contrary to step 7.56 the unit operator reset each half scram after it occurred. Step 7.56 requires the half scram to be reset only after all calibration work was completed and just prior to returning the channel to service. As a result, Unit 2 received several unexpected half scram actuations throughout the performance of 2-SI-4.1B-6(A).

Reasons For the Violation or Findin if Admitted Although the SI did not require the half scram be reset until step 7.56, the unit operator reset the initial half scram generated in step 7.21. The cause of the violation was that this Surveillance Instruction (SI) was inconsistent with. unit operator training.

Page 2 of 13 Enclosure 1 As a noxwial practice, left sealed in for it is undesirable extended to allow a periods.'perators half scram to are instructed be to clear half scrams as soon as possible to minimize the potential of encountering other half scrams from another activity thereby initiating a full scram signal. For this reason, half scrams are generally reset as soon as possible after the half scram condition is cleared.

At, the time of the inspection, there were inconsistent directions to the technicians in the SI and.the Unit Operator on resetting half scrams.

Corrective Ste s Which Have Been Taken and Results Achieved The SI ha" been revised to inform'he Operator oE pending half scrams and to include steps for clearing'alE scrams. This preclude" the recurrence of this inconsistency which led to the miscommunications.

Corrective Ste s Which Will Be Taken to Avoid Further Violations or Findin s Ho further corrective actions are required, Date When Full Com liance Will Be Achieved Full compliance has been achieved.

b. On September 12, 1988, surveillance procedure 2-SI-4.1.B-17(A),

"Reactor Protection System CRD Scram Pilot Air Header Low pressure

.-Calibration," step 7.6.22, was signed off as "H/A" (not applicable) and (procedure) steps 7.6.23 through 7.33 were used to change a transmitter gasket without the use of a maintenance request to provide the SI step numbers to follow in changing the gasket. This is contrary to SDSP 7.6, "Maintenance Request and Tracking," Revision 2, Section 6.0.

Reason., for the Violations or Findin if Admitted The subject SI performs calibration on pressure switches which .

were installed, during the current Unit 2 Cycle 5 outage. These switches are environmentally qualified and require that their cover gasket be replaced each time the cover is removed. During the subject performance of 2-SI-4.1,B-17(A), the switch cover was not required to be removed; therefore, step 7.6.22 of the SI directed 'the performer to "HA" the steps. However, since it was the first time the SI had been performed on the new switches, the technician considered it prudent to replace the gasket, The technician noted this in the remarks section on the SI.

Page 3 of 13 Enclosure 1 At the time this SI was performed, there was no specific direction on the use of "not applicable (HA)" in SIs. Therefore, the technicians HAed step 7.6.22 and subsequent, explanation in tk>e remarks section on the SI review form did not violate requirements of plant procedures. The IMs had a lack of direction in the use of "HA" in SIs.

Corrective Ste s Which Have Been Taken and Results Achieved Instrument mechanics (IMs) received instruction by reviewing, the events documented in this notice of violation. Plant Manager' Instruction (PMI) 17.1, "Conduct of Testing," has been revised to describe the use of HA in SIs. By providing, clarification on the proper use of HA in SIs and procedures, adequate guidance is now available to the technicians to preclude recurrence.

Corrective Ste s Which Will Be Taken to Avoid Further Violations Ho further corrective actions are required.

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

c, On January 30, 1989, the licensee failed to follow PMI-17.1 "Conduct of Testing" in that an unanticipated fuel oil pressure alarm received during the performance of surveillance procedure O-SI-4.9.A.l.a(A), "Diesel Generator "A" Monthly Operability Test," was not documented as a test deficiency.

Reasons for the Violations or Findin if Admitted Although the personnel had previous experience in performing the diesel generator (D/G) SI, they had not experienced a D/G fuel pressure abnormal alarm on a D/G start. This alarm depends on the operating characteristics'of the individual diesel fuel oil system (e.g., pumps, relief valves). Nevertheless, this unanticipated alarm should have been documented as a test deficiency.

Corrective Ste s Which Have Been Taken and Results Achieved 0-OI-82 and 3-0I-82, "Standby Diesel Generator System Operating Instructions," have been revised to include in the Precautions and Limitations section a statement identifying that the D/G fuel oil abnormal annunciators may alarm momentarily on D/G starts.

Page 4 of 13 Enclosure 1 Corrective Ste s Mhich Mill Be Taken to Avoid Further Violations or Findin s PHI 17.1, "Conduct of Testing," which requires documentation of test deficiencies will be placed in the required reading file for all Operations personnel.

Date Mhen Full Com liance Mill Be Achieved Full compliance will be achieved on July 28, 1989.

d. On February 2, 1989, the licensee failed to follow SDSP.-2.11, "Implementation and Cha'nge of Site Procedures and Instructions,"

in that an Immediate Temporary Change (ITC) was not issued for a typographical error identified by a licensee QC inspector which affected the-performance of surveillance procedure O-SI-4.2.D.1, "Liquid Radwaste Honitor Calibration/Functional Test."

Reasons for the Violation or Findin if Admitted Mhile performing SI O-SI-4.-2.0-1, a Quality Assurance (QA) representative identified an incorrect heading on one of the tables. The procedure inadequacy was brought. to the IHs attention. The IH would normally have stopped and initiated an immediate temporary change in accordance with SDSP 2.11. However, the QA identification was noted after the IHs had completed several additional steps. Since SDSP 2.1 requires prompt report.ing and updating of procedures which are found to contain errors, the responsible Instrument Specialist was immediately contacted. The specialist recommended that since the SI performance was not affected, the IHs should continue the SI and initiate a SDSP Form 223, "Procedure Change Resuest," per SDSP 2.1 upon the completion of the noted SI.

I The IHs were inattentive to details; therefore, they did not note the typographical error while performing the affected step, Corrective Ste s Mhich Have Been Taken and Results Achieved O-SI-4.2.D-1 has been revised to change the incorrect table heading.

IHs have received training on the events in this notice of violation. IHs have been instructed to stop and initiate a required procedure change when necessary. Additionally, the IHs were counseled to pay more attention to detail when performing instructions. This instruction should preclude the recurrence of this type of failure.

0 Page 5 of 13 Enclosure 1 Corrective Ste s Mhich Mill Be Taken to Avoid Further Violations or Findin s Ho further corrective actions are required.

Date Mhen Full Com liance Mill Be Achieved Full compliance has been achieved.

e. On January 30, 1989, the*licensee failed to follow calibration procedure LCI-2-L-63.1, "Loop Calibration Instruction Standby Liquid, Control System Tank Level Instrumentation," Step 7.41.3, in that technicians did not insert the full 11 feet of copper tubing into the sensing line of the standby liquid control tank to clean out boric acid crystals as required by the procedure.

r Reasons for the Violations or Findin if Admitted The subject instruction depicts the insertion of a copper tube into a sense line to clean the line of possible accumulation.

During the perfonnance of LCI-2-L-63-1, the performers noticed that the end of the copper tube being used had been damaged. They then proceeded to cut off this damaged section (approximately 3 inches) to preclude potential binding of the copper tubing in the sensing line. However, they did not remeasure the tube to ensure that there was 11 feet as required by the instruction.

The IHs were inattentive to details for not complying with the instruction. Hamely, they did not obtain another 11 foot piece of copper tubing before performing the required step.

Corrective Ste s Mhich Have Been Taken and Results Achieved Instrument Hechanics have been counseled on attention to detail in the perfox~nce of SIs.

Corrective Ste s Mhich Mill Be Taken to Avoid Further Violations or Findin s Ho further corrective actions are required.

Date Mhen Full Com liance Mill Be Achieved Full compliance has been achieved,

Page 6 of 13 Enclosure 1

f. On Febniary 2, 1989, the licensee failed to follow SDSP-2.11, "Implementation and Change of Site Procedures and Instructions",

in that during the perfonnaxxce of standax.d calibration instruction SCI-504.0, "Differential Pressure Transmitter GE Type 555," an operator performed valve manipulations without changing SCI-504.0 to include the required valve manipulations.

Reasons for the Violation or Findin if Admitted Standard Calibration Instruction (SCI) 504.0, which is a generic instruction for calibrating the GE type 555 differential transmitters at BFN, did not contain a step to close root valves while performirig the calibration. The IMs requested that

'pexations provide an Assistant Unit Operator to manipulate root valves and documented the configuxation change on ISMI-3014, attachment 3 since the valve configuration on the root valves for the emergency equipment cooling water system did not conform to the configuration for other GE type 555 instruments at BFN.

The IHs failed'to revise a generic procedure that did not contain the required steps for the noted valve manipulations.

Corrective Ste s Mhich Have Been Taken and Results Achieved IHs have been instructed to stop instxmctions and initiate required changes when necessaxy. Additionally, the IMs received instruction on the examples in this notice of violation to ensure procedural compliance and to preclude recurrence.

Cox.rective Ste s Mhich Mill Be Taken to Avoid Further Violations ox Findin s No furthex. corrective actions are required.

Date Mhen Full Com lienee Mill Be Achieved Full compliance has been achieved.

g. On February 1, 1989, during the calibration of "A" Standby Gas Treatment HEPA Filter Pressure Differential Gauge per Standard Calibration Instruction, SCI-527, "Calibration of "A" Standby Gas Treatment HEPA Filter Pressure Differential Dryer Magnehelic DP Gauge," the technicians performed valve manipulations without changing SCI-527 to include valve manipulations needed to isolate and x.'estox.e the tested DP gauge as required by SDSP-2.11, "Implementation and Change of Site Procedures and Instructions."

Page 7 of 13 Enclosure 1 Reasons For the Violation or Findin if Admitted SCI 527, "Calibration of "A" Standby Gas Treatment HEPA Filter Pressure Differential Dryer Magnehelic D. P. Gauge," is- a generic instruction which did not contain steps to isolate the gauge before performing the calibration. The affected gauges are in a series configuration and require several valve manipulations during the performance of the calibration instruction.

Although the IHs documented each valve manipulation on IMSI-3014, Attachment 3, they did not revise the instruction to include the requiz.ed manipulations.

Corrective Ste s Mhich Have Been Taken and Results Achieved SCI-527 has been revised to include a step to isolate the D.P. Gauge and to document required changes in IMSI-3014, attachment 3. IMs have received training on the events in this notice of violation. Also, IMs have been instructed to stop and initiate a required procedure change when necessary.

Corrective Ste s Mhich Mill Be Taken to Avoid Further Violations or Findin s Ho further corrective actions are required.

Date Mhen Full Com lienee Mill Be Achieved Full compliance has been achieved.

h. On July 18, 1988, procedure SCI-204, "Differential Pressure Transmitter, GE Type 555, (Range 0-200 inches water)," Step 7.2, was not followed 'in that configuration control forms were not completed for isolation and return to service of 2-LT-3-206 as required by the procedure. Since this documentation does not exist, there is no confirmation that. second person verification of the isolation and return to service was performed.

Reason for the Violation or Findin if Admitted At the time of this inspection, the inspector was not provided the restart test information for review. Although second person verification was documented, this calibration was performed as part. of a unit 2 restart test.

Page 8 of 13 Enclosure 1 The calibration of transmi.tter 2-LT-3-206 took place in conjunction with the perfonnance of Restart, Test 2-8'-RTP-003B.

"The transmitter was isolated, including second person

..verification, in accordance with this restart test {step 5.2;42) on July 14, 1988, in conjunction with a maintenance request.

Since the transmitter was in calibration, credit. was -taken. for the transmitter s x.'outine calibration. On July 22, 1988, in accordance with the restart test (step 5.2.54.5),

transmitter, 2-LT-3-206 was returned to service, including second party verification.

Corrective Ste s Which Have Been Taken and Results Achieved Documentation of second"person verificati.on for the isolation and return to service of. 2-LT-3-206 was located in 2 BFH-RTP-0038.

Corrective Ste s Which Wi'll Be Taken to Avoid Further Violations or Findin s Ho further corrective actions are required.

Date When Pull C liance Millage Achieved Full .compliance .has keen achieved.

I i..--On February 1, 1989; the licensee failed to follow SDSP-2.1, 'Mite px;ocedures and Instxwctions," in that during perfox~nce of standard calibration instruction SCI-511, "Standard EECM System Calibration,'echnicians'failed to,verify %he appropriate

-revision to be used and recorded infornxation on the calibration card 'bg ut.i1izing Revision '2 of procedure .SIHI-67, emergency Equipment Cooling Water System," when Revision'3 should have been used. Revision 2 of SIMI-67 had a,2% instrument accuracy and Revision 3 had a 1..3V -instrument accuracy which was more conservative Seasons for the Violation or Findin if Admitted

.SCI 511 was to be performed on an emergency equipment, cooling water system indicator. 'The ca1ibration data cards were prematurely filled out using.a controlled copy of 'O-SINAI-67 <iled in the instrument shop library. Additionally, the 3Zs did not verify that. they, were, using the latest revision .of.,O-SIMI-67. .The

%C inspector asked the IMs if they used the latest. revision of O-SIMI-67, One of the IMs made a call to Document Control and was informed that 'revision 3 of O-,SXK-67 had been issued.

Therefore, the IKs used an out.-of-date instruction to complete calibration cards.

Page 9 of- 13 Enclosure 1 Corrective Ste s Which Have Been Taken and Results Achieved The" IHs obtained revision 3 from Document Control and made the necessary corrections to their calibration data cards. SCI-511 has been revised to require IMs to verify that they have the latest revision of the instruction. IHs have received training on the events in this notice of violation.

Corrective Ste s Which Mill Be Taken to Avoid Further Violations Ho further corrective actions are required.

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

2. Contrary to the above, during the performance of SIs and instrument calibration that had been validated by the licensee, procedures were not adequately established in the following examples:

Admission or Denial of the Alle ed Violation TVA admits each event of this violation and will address the reason for the violation (oz. finding) if admitted, the corrective actions which has been taken and the results achieved, the corrective action which will be taken to avoid further violations (or findings) and the date when full compliance will be achieved.

a. On January 30, 1989, surveillance procedure 2-SI-4.1B-6(A),

"Reactor Protection and Primary Containment Isolation Systems Low Mater Level Instrument. Channel A1 Calibration," was not adequate in that during the performance of steps 7.40.2, the Gross Fail Latch LED was not illuminated and the step was initialled as being H/A (not applicable); however, after completion of steps 7.40.3 and 7.40.4, the Gross Fail Latch LED was illuminated and step 7.40.5 could not be performed as written. Additional actions, which were required to perform step 7.40.5 by resetting the Gross Fail Latch (LED) and continue the SI; were not included

. in the approved procedure.

Reasons for the Violations or Findin if Admitted These particular steps of 2-SI-4.1.B-6(A) deal with the setting of the low gross failure of an analog trip unit. (ATlJ). In order the low gross failure setpoint,, two calibration current to'heck sources contained within the calibration unit are used the stable current source and the transient current source. (Both current sources are controlled by potentiometers on the

Page 10 of 13 Enclosure 1 calibration unit.) Whenever the calibration unit is supplying, current to the analog tx'ip unit, the stable current source is supplying that current. However, the transient cuxrent source is periodically switched in and out and provides an additional calibration signal to the stable current. During the performance of steps 7.40.3 and 7.40.4 in the subject SI, the transient current source was switched in without regard to the setting of its potentiometer. This potentiometer setting provided a high calibration signal which caused the setpoint to be exceeded.

Corrective Ste s Which Have Been Taken and Results Achieved The -ubject SI has been revised to ensure the transient current source potentiometer is turned fully counterclockwise befoxe connecting it to the ATU.

Coxrective Ste s Which Mill Be Taken to Avoid Further Violations ox Findin s The SIs which involve calibration of applicable analog trip units will be revised to ensure the transient current soux'ce's potentiometer is turned fully counterclockwise befoxe activating the transient current source.

Date Mhen Full Com liance Mill Be Achieved Full compliance will be achieved by August 1, 1989.

b. On January 30, 1989, calibration procedure LCI-2-L-63-1, "Loop Calibration In..txuction Standby Liquid Control System Tank Level Instrumentation," step 7.41.3, which requires inserting of 11 feet of copper tubing into the sensing line in the standby liquid control tank, was not adequate in that as-constructed drawing 47M600-56 shows that the sensing line is 11 feet long inside the tanks with -approximately 8 inches of piping extending above the tank where the cleanout tubing is inserted. This resulted in failure to completely rod out the sensing line to clean out any boric acid crystal buildup.

Reasons for the Violations or Findin if Admitted The standby liquid control tank level is monitored using a "bubbler" level system. In this level monitoring system if the sense line were to become clogged, the level indication would be inaccurate. Mith the new sodium pentaborate solution being used at BFH Unit 2, there is a low probability that the solution will be solidified in the sense line. However, loop calibrat,ion instruction 2-L-63-1 required the sense line to be cleaned. on a basis. An 11 foot piece ot coppex tubing was incorrectly 'eriodic specified because of a lack of detail during proceduxe preparation.

Page 11 of 13 Enclosure 1 Corrective Ste s Which Have Taken and Results Achieved LCI-2-L-63-1 has been revised to require 12 feet of copper tubing to clean the sense line. This length is. sufficient to extend to the bottom of the sense line.

Corrective Ste s Mhich Will Be Taken to Avoid Further Violations or Findin s Ho further corrective actions are required.

Date When Full Com liance Mill Be Achieved Full compliance has been achieved.

c. On February 2, 1989, during the performance of calibration instruction SCI-504.0, "Standard Calibration Instruction Differential Transmitter GE Type 555, (Range 0-391 inches water),"

the procedure was determined to be inadequate for the performance of the calibration of 0-FT-67-3A in that root valve manipulations required for satisfactory procedure completion were not addressed in the procedure.

Reasons for the Violation or Findin s if Admitted The manipulation of these root valves was also addressed as a craftsman deviation event (1.1.F) in this notice of violation.

SCI 504.0 is a generic instruction for calibrating the GE type differential transmitters at BFH. This instruction was used to calibrate the emergency equipment cooling water (EECW) system transmitter on February 2, 1989. SCI 504.0 did not contain specific ..teps to manipulate valves. The valve manipulations were documented using IHS1-3014, attachment 3.

Corrective Ste s Mhich Have Been Taken and Results Achieved SCI 504 has been revised to incorporate required steps to manipulate the root valves on the FECW system and to document those manipulations on IHSI-3014, attachment 3.

Corrective Ste s Mhich Mill Be Taken to Avoid Further Violations Ho further corrective actions are required.

Date Mhen Full Com liance Mill Be Achieved Full compliance has been achieved.

Page 12 of 13 Enclosure 1

d. Calibration procedure SCI-527, "Calibration of "A" Standby Gas Treatment HEPA Filter pressure Differential Gauge," did not address isolation valve manipulations required to isolate and place back in service the tested DP gauge from the two other DP gauges.

Reasons for the Violation or Findin if Admitted The manipulation of these root valves was also addressed as a craftsmen deviation event (1.1.G) in this notice of violation.

SCI-527 is a generic instruction for calibrating the "A" Standby Gas Treatment HEPA Filter Pressure Differential Dryer Megnehelic L.P.Gauge. This instruction did not contain specific steps to isolate the gauges for p'erforming the calibration.

Corrective Ste s Mhich Have Been Taken and Results Achieved SCI 527 has been revised to add steps to perform the required valve manipulations.

Corrective Ste s Mhich Mill Be Taken to Avoid Further Violations or Findin s Ho further corrective actions are required.

Date Mhen Full Com liance Mill Be Achieved Full compliance has been achieved.

10 CFR 50, Appendix B, Criterion XVII, Quality Assurance Records, requires that sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include at least the, following: operating logs and the, results of reviews, inspections, tests, audits, monitoring of, work performance, and materials analyses. The records shall also include closely-related data such as qualifications of personnel, procedures and equipment. Contrary to the above, calibration cards used to record vital instrument information and calibration results were not controlled by plant administrative procedures as QA records.

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

Page 13 of 13 Fnclosure 1 Reasons For the Violations or Findin if Admitted Some generic calibx.'ation instructions x.equixe instrument mechanics to obtain instrument setpoint, accuracy, and range information from calibration cards. Calibration cards are handled as QA records in regard to storage of data. Completed cards are transmitted to permanent storage and microfiled. The cards are retuxmed and filed in the instrument shop.

These cards, at that point, are not treated as QA records and therefore ax;e uncontx.oiled. Referrixxg to these cards to obtain calibration information as described above constitutes the obtaining of data from an uncontx.oiled source.

These instxmctions also requix.'e IMs to record data on calibration cards without administrative guidance on how to fill out calibration cards.

Corrective Ste s Mhich Have Been Taken and Results Achieved IHs have been instxwcted that uncontrolled sources shall not be used to obtain calibration information on technical specification or instruments. othex'afet,y-related The particular instxwct,ion in which this problem was found, Standard Calibration Instruction (SCI) 511, has been revised to refer to the applicable system inst.raiment maint;enance indexes (SIMIs) for calibration information.

Cox..rective Ste s Mhich Mill Be Taken to Avoid Further Violations or Findin s Calibration infox~>ation should be controlled by SIMIs on each syst.em.

These SIHIs are issued as maintenance instructions. In instances where SIHls do not contain this information, SIMIs are revised to include the i appropriate information.

Calibration instructions which require IMs to obtain calibration information from calibration cards are being revised to refer to system indexes for the source of calibration information.

instruction been issued to give instrument mechanics guidance on An how to fillouthascalibration cax;ds.

Date Mhen Full Com liance Mill Be Achieved 1Jnit 2 calibration instructions for safety-related instruments which IMs to obtain calibration data from calibr'ation cards will be '.'equire revised by September 25, 1989 to refer to system indexes fox the source of calibration infoxmat.ion.

0 0

ENCLOSURE 2 RESPONSE TO DEVIATION HRC IHSPECTIOH REPORT HOS. 50-259/89-06, 50-260/89-06, AHD 50-296/89-06 LETTER FROH B. A. WILSON TO 0. D. KINGSLEY, JR.

DATED HAY 8, 1989 The TVA Browns Ferry Nuclear Performance Plan (HPP), Volume 3, Revision 1, Section II, paragraph 5.0, "Plant Surveillance Program," committed to ensure that all applicable Surveillance Instructions (SIs) were acceptable by conducting a review process which included procedure verification, review, walkdown, and validation.

Contrary to the above, the commitment was not met in that HRC inspectors witnessed numerous SIs that had already been validated and documented as validated on the computer printout entitled "SI Status List", but the SI procedures either: (1) could not be performed as written', (2) required valve manipulations that were omitted from the procedure; (3) contained steps for "out of tolerance" conditions requiring calibration of Technical Specification instruments required for fuel load that had not been validated; oz. (4) contained errors that resulted in an inade'quate surveillance test. Specific example- of the SI deficiencies are documented in the details of the inspection report.

Rea on for the Deviation The HPP Volume 3, Revision 1, committed TVA to validate SIs in accordance with SDSP 2.14. SDSP 2.14 required only a sampling (10 percent) of the SIs to be independently validated. These SIs were validated by a first-run perfonnance. The first-run performance only validated the steps performed and not necessarily all steps. These SIs were not,independently validated.

Hany of the reported events depict administrative errors in the SIs. As a result of thi" inspection, the SI validation process was strengthened to minimize these types of errors. However, these errors did not adversely affect the instruments being calibrated or their operability. TVA contends that the SI upgrade program was effective.

Additionally, the calibration instructions were never a part of the SI upgrade program depicted in HPP Volume 3, Revision 1. These instructions included the valve manipulations that were not included in the procedure. The reason these instruction: were not included in the SI upgrade program is that the affected instruments do not monitor a technical specification requirement.

Corrective Ste s which Have Been Taken and the Results Achieved The plant formed a SI task force to evaluate the surveillance program and to make recommendations for improving the program. The task force reviewed:

Training on cond~et of testing, procedure reviews, scheduling, and personnel accountability. The SI task force has provided its recommendations to the Plant Hanager for implementation. Additionally, the task force is currently tracking open action item:; thereby, ensuring the enhancements are implemented.

0 Page 2 of 2 EHCLOSURE 2 SDSP 7.4, Procedure Review," has been revised"to incorporate the task force's recommendations; IHPO S4-020, "Good Practices", and HlJREG/CR-1369, Revision 1 (i.e., Procedures Evaluation Checklist for Maintenance, Test, and Calibration procedures used in Huclear Power Plants). Many of the events identified in this violation are <<ow addressed in attachment A (verification check list question) of this procedure. (For example, in attachment A, question 49 is:

Does the procedure agree with applicable drawings (IHPO 84-021, R1, Quest.ion 111.1.2)2 This question describes the HRC concern identified in example A.2.b.) Finally, the revised SDSP 7.4 has been revised to establish a f'onnal process,to validate the SIs and other man-machine interface procedures.

Corrective Ste s Mhich Mill Be Taken to Avoid Further Deviations Programmatic changes necessary to avoid further deviations have been implemented.

Mhen Corrective Actions

'ate.

Mill Be Com leted Full compliance has been achieved.

EHCLOSURE 3 LIST OF COMMITMEHTS HRC IHSPECTIOH REPORT HOS. 50-?59/89-06, 50-260/89-06, AHD 50-296/89-06 LETTER FROM B. A. MILSOH TO 0. D. KIHGSLEY, JR.

N DATED MAY 8, 1989

1. Plant Manager. Instruction (PMI) 17.1, "Conduct of Testing," which de..cribes the need to document test deficiencies will be placed in the required reading file for all Operations personnel by July 28, 1989.

2. Surveillance Instructions which involve calibration of applicable analog trip units will be revised to ensure the transient current source potentiometer is turned fully counterclockwise before switching in the transient current source. This will be completed by August 1, 1989.

3. Unit. 2 calibration instructions for safety-related instruments which require Instrument Mechanics to obtain calibration data from calibration "

card - will be revised by September 25, 1989 to refer to system indexes for

. the source of calibration information.

~~

~