ML18033A902
| ML18033A902 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/22/1989 |
| From: | Michael Ray TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8908250322 | |
| Download: ML18033A902 (15) | |
Text
- PC CE1ZRATED DISTMBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATXON DISTRIBUTION SYSTEM (RIDS)
SSION NBR:8908250322 DOC.DATE: 89/08/22 NOTARIZED: NO DOCKET I
'XL: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 Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFXLIATION RAY,M.J.
Tennessee Valley Authority RECIP.NAME RECIPXENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Forwards util response to 3 open items identified in Section 3.0 of Insp Repts 50-259/89-07,50-260/89-07 6 50-296/89-07.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:1 Copy each to: B.Wilson,D.M.Crutchfield,B.D.Liaw,S.Black R.Pierson, 1 Copy each to: S.Black,D.M.Crutchfield,B.D.Liaw, R.Pierson,B.Wilson 1 Copy each to: S. Black,D.M.Crutchfield,B.D.Liaw, R.Pierson,B.Wilson 05000259 05000260 05000296 D
RECIPIENT XD CODE/NAME PD I
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5 RECIPIENT ID CODE/NAME GEARS,G AEOD AEOD/TPAD LOIS, ERASMIA NRR/DEST DIR NRR/DOEA DIR 11 NRR/DREP/RPB 1 0 NUDOCS-ABSTRACT OGC/HDS2 RES MORISSEAUID NRC PDR COPIES LTTR ENCL 1
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TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 3740t 5N 1578 Lookout Place U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Hashington, D.C.
20555 Gentlemen:
In the Matter of Tennessee Valley Authority Docket Nos.
50-259 50-260 50-296 BRONNS FERRY NUCLEAR PLANT (BFN) RESPONSE TO NRC INSPECTION. REPORT NOS.
50-259/89-07, 50-260/89-07, AND 50-296/89-07 This letter transmits TVA's response to the three open items identified in section 3.0 of the subject report.
The response for these items is contained in Enclosure l.
A summary list of commitments is provided in Enclosure 2.
The inspection report, which was issued on June 30, 1989, requested that TVA provide a response within 30 days.
- However, TVA did not receive this report until July 10, 1989.
An extension of the response due date to August 23,
- 1989, was agreed to by G. Gears in a telephone call.
Please refer any questions concerning this submittal to Patrick P. Carier, BFN, Site Licensing (205) 729-3570.
Very truly yours, TENNESSEE VALLEY AUTHORITY Mana r, Nuclear icensing and Regulatory Affairs Enclosures cc:
See page 2
8.08250822 8W0822 PDR ADOCK 05000259 0
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An Equal Opportunity Employer
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AUB RR $89 cc (Enclosures):
Ms. S.
C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One Nhite Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Ni lson, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NN, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637
- Athens, Alabama 35609-2000 0
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ENCLOSURE 1
NRC Concern The voltage profile calculations for the 4160V Shutdown Board A battery did not consider the maximum value of the surge currents present in the first minute of the duty cycle.
The NRC team noted that the battery calculations did not use the maximum transient current value for a minimum of one minute, as recommended in IEEE standard 485-1983, when performing voltage profile calculations.
All other battery calculations except this one used the maximum transient current value recommended by the IEEE Standard.
The calculation used a lower value of current based on the estimated duration of the current surge.
If the maximum estimated current is used, the battery capacity is insufficient to support the duty cycle while maintaining a minimum required voltage of 210VDC.
TVA needs to find out why the battery calculation did not consider the maximum value of the surge currents.
TVA Res onse
.TVA maintains that the existing calculations are technically adequate and demonstrate the capability of the 4160V shutdown board batteries to satisfy their design basis requirements.
While TVA did depart from a strict application of the standard method, it did so based upon guidance and supplemental technical data (calculations and testing) provided by the battery manufacturer.
TVA contends that use of this data in conjunction with the basic IEEE Standard 485 method most accurately represents the true capacity of the battery.
The battery manufacturer has performed for TVA both. a. cell sizing calculation and a voltage profile analysis for the actual'FN 250 VDC shutdown Board Battery duty cycle.
The calculations conclude that the 4160V shutdown board's DCU-9 batteries are capable of supplying the first minute duty cycle plus random loads without falling below the required minimum voltage.
In summary TVA has utilized manufacturer' data in conjunction with the basic method of IEEE 485 (Note:
TVA is not committed to IEEE 485 at BFN) to analyze the actual battery duty cycle.
TVA's calculations document battery adequacy and are independently verified by calculations performed by the battery manufacturer.
Therefore, TVA has ensured the technical adequacy of 4160V shutdown board battery system.
NRC Concern 2.
Automatic Depressurization System (ADS) elementary diagram 2-730E929 indicated that the Alternating Current (AC) interlock, used to ensure low pressure core cooling availability before ADS is initiated, would not work properly.
Pressure switches connected to RHR B and D pumps were incorrectly connected to RHR relays K102B and K103B.
Loss of one battery or one diesel could disable both redundant trains of ADS.
TVA needs to establish the correct plant configuration and revise the ADS elementary diagram.
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TVA Res onse Page 2 of 3 During the system plant acceptance evaluation (SPAE) drawing upgrade
- process, TYA identifiers were assigned to components which were previously only identified by GE component identifiers.
The contractor performi,ng the upgrades made an error in the assignment for pressure switch PS-10-120D which should have been TVA number PS-74-42A rather than PS-74-31B and PS-10-123B which should have been PS-74-31B rather than PS-74-42A.
The GE 2-730E937 drawing series are not used in the field for installation but are the basis for developing the connection diagrams which are used for installation.
The connection diagram (TVA drawing 45N2635-3) shows:
GE Device No PS-10-120B PS-10-120D PS-10-123B PS-10-123D TVA Device No PS-74-31A PS-74-42A PS-74-31B PS-74-42B By using those assignments, it can be seen by wire tracing that PS-10-120B (PS-74-31A) and PS-10-120D (PS-74-42A) are associated with relay 10A-K1028 and PS-10-123B (PS-74-31B) and PS-10-123D (PS-74-42B) are associated with relay 10A-K1038 which is the way it was shown on GE elementary diagram 2-730E937 Sheet 9 before the TVA identifiers were incorrectly added to it.
Also, during the SPAE drawing upgrade process GE identifier PS-10-120A was assigned TVA number PS-74-8 which should have been'S-74-8A as shown on the connection diagram (TVA drawing 45N2635-3).
This has been determined to be a drafting error which omitted the "A".
Since the mislabelling errors on the GE 2-730E937 drawing series did not affect the connection
- diagram, and the installation of the pressure switches occurred prior to the mislabelling, this error could not have caused a wiring error in the field.
TVA has corrected the sub]ect drawing errors and will perform a review to correct similar type errors to close Engineering Assurance Oversight Review Team Action Items E-051 and E-052.
GE boiling water reactor facilities of the BFN vintage utilize a design basis that provides ADS in combination with low pressure reactor coolant
'upplies as the redundant and diverse method to high pressure coolant injection (HPCI) for reactor makeup given small and intermediate size pipe breaks in the reactor coolant pressure boundary.
Therefore, ADS and HPCI are assigned to divisional power supplies I and II respectively.
It should be noted that the ADS is not single failure proof by itself.
However, owing to concerns with a pipe break which disables
- HPCI, an analysis (GE Topical Report NEDO-24266) was performed to ensure that adequate core cooling would be maintained if ADS was affected by a single DC battery failure.
The analysis results were shown to be acceptable.
Page 3 of 3 NRC Concern 3.
The Calculation Cross Reference Information Systems (CCRIS) is seen by the NRC team as one of TVA's primary means of tracking and managing information generated and used in the calculations.'owever, many errors were found within the CCRIS database involving references that were used in the calculation but were not in CCRIS; some calculations were also miscategorized.
The NRC team attributed most of these errors to the improper inputting of data into CCRIS.
TVA needs to provide some additional training to the users of CCRIS with particular emphasis on the purpose and goals of CCRIS and the proper inputting of data into CCRIS.
TVA Res onse Browns Ferry Engineering Project-is committed to effectively implementing the CCRIS.
Present procedures require the implementation and maintenance
~ of CCRIS.
The discrepancies identified during NRC audit were previously
- identified in the Engineering Assurance oversight review and documented in Condition Adverse to Quality Report (CAQR)
BFE 880646.
The CAQR corrective action for the CCRIS requires additional training in the area of implementation and correcting existing problems.
Therefore, the CAQR corrective action will track the resolution of this concern and will be completed before restart of unit 2.
ENCLOSURE 2
Summary List of Commitments The following commitments, contained in this submittal and in Inspection Report 50-259/89-07, 50-260/89-07, and 50-296/89-07, will be addressed by the Nuclear Performance
- Plan, Volume 3 commitments for DBVP.
TVA will track followup,and ensure completion in accordance with Volume 3 and does not consider these as new commitments.
Before restart TVA has corrected the subject drawing errors and will perform a review to correct similar type errors to close Engineering Assurance Oversight Review Team Action Items E-051 and E-052.
2.
3.
4.
5.
The Condition Adverse to Quality Report (CAQR)
BFE 880646 corrective action for the CCRIS requires additional training in the area of implementation and correcting existing problems.
Therefore, the CAQR corrective action will track the resolution of this concern and will be completed before restart of unit 2.
(P/L item ¹ 2-2217)
TVA's proposed corrective actions are to revise the BFN Rigorous Analysis Handbook to require that equipment nozzle thermal displacements 1/16-inch or greater be considered, and to review a sample (5 or 6) of the 40 small-bore stress packages already prepared to confirm that this requirement has been met.
(P/L item ¹ 2-2230)
The branch line anchor point movements for a sample of the 40 small-bore pipe stress packages already prepared wi 11 be checked against the computed branch line anchor point movements in the'arge-bore pipe stress packages.
(P/L item 2-2231)
The BFN Rigorous Analysis Handbook will be revised to specify 70'F as the reactor building datum ambient temperature, and the applicable calculations will be revised in accordance with this requirement.
(P/L item ¹ 2-2233) 6.
7
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TVA will prepare a response to address concerns regarding calculation requirements for the hydrostatic test condition.
(P/L item ¹ EA C-092)
The pipe sleeve clearance evaluation sheets for calculation CD-Q2074-88991 will be revised to correct transposed global X and Z plan coordinates.
(P/L item ¹2-2232) 0 8.
9.
10.
CCRIS will be revised to show the BFN environmental drawings as predecessors to calculation ND-Q2000-87004.
(P/L item ¹ 2-2220)
CCRIS input errors will be corrected.
(P/L item ¹ 2-2217)
Vendor information will be used as input to the calculation and will be identified in the CCRIS sheets.
(P/L item ¹ 2-2219)
Page 2 of 2 Calculations for Equipment Qualification, Appendix R,
and Secondary Containment will be included, as applicable, in the essential calculation list.
(P/L item ¹ 2-2235) 12.
13.
The NTB calculations in the hreas of EQ, secondary containment and
- hazards, and those identified as missing and being regenerated, will be audited on a sample basis.
(P/L item ¹ 2-2218)
Configuration dependent calculations will be reviewed against plant modifications.
(P/L i tern ¹ 2-2229) 14.
The calculation for 2-PT-64-56A will be revised to state that any single failure will not prevent initiation of a safety system.
(P/L item
¹ 2-2222) 15.
Corrective action for CAQR BFE 880646 will require review of changes to contractor calculations where no independent reviews were performed.
(P/L item
¹ 2-2217) 16.
Revise calculation ED-Q2064-88103 to use the vendor specified seismic induced error of 0.5 percent of the upper range limit.
(P/L item
¹ 2-2222) 17.
Review and revise as required the Technical Specification instrument set-point scaling calculations to account for a 25 percent calibration interval extension.
Complete revisions for those calculations where the error affects the conclusions.
(P/L item ¹.2-2226).
18.
19.
Perform a detailed comparison of CAD generated drawings against the last hardcopy revision to correct CAD entry errors.
(P/L item ¹ E-051)
Audit an additional sample of contractor generated instrumentation and control calculations.
(P/L item ¹ 2-2218)
After Restart 20.
21.
Nhen pipe stress calculation package CD-Q2074-88750 is revised, TVA will add the correct pipe support load transmittal.
(P/L item ¹ 2-2234)
The instructions for the diesel generator 18-month load-acceptance surveillance test will be revised to provide for inspection and/or testing to confirm proper regulator and governor tuning.
(P/L item
¹ 2-2224) 22.
Review and revise as required the Technical Specification instrument set-point scaling calculations to account for a 25 percent calibration interval extension.
Complete revisions for those calculations where the effort has no affect on the conclusions.
(P/L item ¹ 2-2225)
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