ML18033A940
| ML18033A940 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/05/1989 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8909120185 | |
| Download: ML18033A940 (9) | |
Text
REGULATORY INFORA~TION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:8909120185 DOC.DATE: 89/09/05 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 Station, Unit 3, Tennessee 05000296
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UTH. NAME AUTHOR AFFXLIATION DFORD,M.O.
Tennessee Valley Authority ECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)'UBJECT:
Responds to NRC 890804 ltr re violations noted in Xnsp Repts 50 259/89 20I50 260/89 20 6
50 296/89 20
'ISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR /
ENCL L SIZE:.5 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 ID CODE/NAME PD INTERNAL: ACRS AEOD/DEIIB DEDRO NRR SHANKMAN,S NRR/DLPQ/PEB t
NRR/DREP/EPB 10 NRR/PMAS/ILRB12 OE LIEBERMAN,J G FXLE EXTERNAL: LPDR NSIC NOTES:
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TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 6N 38A Lookout Place SEP 05 1989 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of Tennessee Valley Authority Docket Nos.
50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) UNITS 1, 2, AND 3 NRC INSPECTION REPORT NOS. 50-259/89-20, 50-260/89-20, AND 50-296/89-20
RESPONSE
TO NOTICE OF VIOLATION TECHNICAL SPECIFICATION 3. 5.8. 9 t
This letter provides TVA's response to the notice of violation transmitted by letter from B. A. Wilson to 0.
D. Kingsley, Jr.
dated August 4, 1989.
The report cited TVA with a violation for failure to meet technical specifications requirements for operable residual heat removal pumps and a deviation on the failure to conduct technical staff and managers orientation training for Modification engineers as committed in TVA's Nuclear Performance
- Plan, Volume 3, Revision 2.
The enclosed information responds to NRC concerns regarding inadequacy in tne area of electrical connections, postmodification test, and operability surveillance.
On August 29,
- 1989, a telephone call was made to William S. Little of your staff to extend the due date of the response on the deviation from September 3,
1989, to September 17, 1989.
Enclosure 1 provides TVA's response to the violation in the subject report.
A list of commitments is provided in enclosure 2.
39091..A I. 8;-
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PDC An Equal Opportunity Employer
SEP 05 $89 If you have any questions, please telephone Patrick P. Carier, BFN, at (205) 729-3570.
Very truly yours, TENNESSEE VALLEY AUTHORITY Mark O. Medford, Vice President and Nuclear Technical Director Enclosures cc (Enclosures):
Ms.
S.
C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One Hhite Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Nilson, 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
ENCLOSURE 1
RESPONSE
TO VIOLATION NRC INSPECTION REPORT NOS. 50-259/89-20, 50-260/89-20, AND 50-296/89-20 LETTER FROM B. A.
WILSON TO O.
D.
KINGSLEY, JR.
DATED AUGUST 4, 1989 Violation A Technical Specification (TS) 3.5.8.9 requires that at least one RHR loop with two pumps or two loops with one pump per loop be operable when the reactor vessel pressure is atmospheric and irradiated fuel is in the reactor vessel.
TS 3.5.D.1 requires that the equipment area cooler associated wit'ch RHR pump be operable at all times when the pump served by that specifl
. cooler is considered to be operable.
TS 3.5.D.2 states that when an equipment area cooler is not operable, the pump served by that cooler must be considered inoperable for TS purposes.
Contrary to the above, during the period of May 10-25,
"uring this period, only RHR Loop I pump "A" was operable, the RHR Loop II pump. ("B" and "D") were inoperable for a scheduled
- outage, and RHR Loop I pump "C'as inoperable due to its associated pump area cooler fan motor rotation being reversed.
Admission or Denial of the Alle ed Violation TVA admits the violation.
Reasons for the Violation The violation occurred as a result of a failure to properly follow the workplan test instruction which required that proper fan rotation be checked.
The root cause of this failure is personnel error.
The responsible Modifications engineer and independent verifier signed the step in the workplan verifying the proper rotation of the 2C residual heat removal (RHR)
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room cooler fan without observing the fan's rotation.
Another contributing factor was'the lack of detail in the workplans which did not specify a point of reference for verifying the proper fan rotation.
Corrective Ste s Which Have Been Taken and Results Achieved An emergency Maintenance Request was written to troubleshoot and repair the room cooler.
Once verification was made that the fan was operating in a reversed direction, the power cables to the fan motor were rolled to obtain the proper fan rotation an'd airflow direction.
The other three unit 2
RHR room coolers and two core spray room coolers were also tested for proper fan rotation and found acceptable.
room cooler units have two rotation markings which conflict.
The fan ing is marked with a paper sticker showing the correct rotation.
The rs, that are part of the cooler units, are marked with a large brass tag
>nd cating incorrect rotation.
A walkdown of the room cooler units nas been completed and all incorrect rot:ation markings have been identified.
Maintenance Requests have been generated and are being worked to remove or paint over improper rotation markings.
hous moto The Modifications personnel involved were both given oral warnings, and the independent verifier has been trained to the requirements of Site Director Standard Practice (SDSP)-3.15 (independent verification).
In addition, a
review on the adequacy of the procedure for modifications workplans and the methodology for verifying proper equipment rotation has been perfc.~ed.
The procedure for verifying proper rotation, EMI-33, was revised to p~
ide more explicit instructions.
Corrective Ste s Which Will Be Taken to Avoid Further Violation The RHR pump flow rate surveillance instruction (SI) verifies the RHR room coolers are operable at the same time the RHR pump is operable as required by TS 3.5.0.1/4.5.0.1.
The SI accomplishes this requirement by locally verifying that the RHR pump cooler fans auto-start when their respective RHR pumps start.
- However, to ensure adequate flow existed from the room coolers, a
technical instruction (2-TI-134) has been developed for periodic measurements of the unit 2
RHR and core spray room cooler air flows.
This instr ction will.
detect any degraded flows through the room coolers.
It may also be used, as necessary, as a postmodification/postmaintenance test to verify the flow through the cooler was not affected after any modification or maintenance.
To ensure postmodification tests are properly performed, ch'anges will be made to SDSP-17.2, "Post Modification Test Program," to include requirements and qualifications for persons involved in writing and performing postmodification tests.
Where possible, existing maintenance instructions will'e used for postmodification test.
Standardized instructions will be developed for repetitive tests.
These standardized instructions will, as necessary, be included as part of a work plan package.
Date When Full Com liance Will Be Achieved SDSP-17.2 will be revised by September 25, 1989.
LIST OF COhiMITMENTS 1.
SDSP-17.2 wi11 be revised by September 25, 1989;