ML18033B141
| ML18033B141 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/18/1990 |
| From: | Wilson B Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18033B139 | List: |
| References | |
| 50-259-89-53, 50-260-89-53, 50-296-89-53, NUDOCS 9001300151 | |
| Download: ML18033B141 (24) | |
Text
NC'SURE 2
NOTICE OF DEVIATION Tennessee Val icy Authori ty Browns Ferry 1. 2, and 3
Docke.
Nos.
50-259, 50-260, and 50-296 License Nos.
DPR-33, DPR-52, and DPR-68 The followinc deviation was identified during a Nuclear Regulatory Commission (NRC) inspection conducted on November 15 - December 18, 1989.
By letter dated April 1,
- 1988, the licensee notified the NRC that a
LER would not be submitted unde".
nui be.
259/88 04.
The letter sta:ed that the information that would have been reportea in the'ER would be included in Special Report 88-01-.
Con:rary to the
- above, in Ociooer,
- 1989, licensee reviews of the initiating conditions identifiec that tne special report was not sent t,o the NRC.
These reviews also determ!ined tha:
tne conditions were reportable and LER 259/89-25 was issued.
Failure to submit the special report
'.s considered a deviation from a commitmen=. -o the NRC.
This deviation is applicable to ai'i three uni-.s.
Please provide U.S:
Nuclear Regulatory Commission, ATTN:
Document Control Desi;, Washington, DC 20555,.with a copy io.he Associate Director =or Special
- Projects, Office of Nuclea, Reactor Regula ion, and a copy to the NRC Residen Inspector, Browns Ferry'! in'writing wiinin 30 days of the date of this Notice, the reasons for the deviation, the corrective steps which have been taken and the results
- achieved, the corrective steps which will be taken to avoid further deviations, and the date when your corrective action will be completed.
Where good cause is, sho~n.
consiceration will be given to extend'ng the respons'e
-.ime.
FOR THE NUCLEAR REGULATORY COiviNISSION il~!
Bruce A. Wilson, Assistant Director for Inspection Programs TVA Projects Division Office of Nuclear Reactor Regulation Dated at Atlanta, Georgia this )~">>'day of January 1990
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 101 MARIETTA ST R E ET, N AV.
ATLANTA,GEORGIA 30323 Report Nos.:
50-259/89-53, 50-260/89-53, and 50-296/89-53 Licensee:
Tennessee Valley Authority 6N 38A Lookou-. PiacE 1101 Yiarl'e Street Chattanooga.
TN 3740"-280 Docket Nos.:
50-259, 50-260, and 50-296 License Nos.:
DPR-33, DPR-52, and DPR-68 Facility Name:
Browns Ferry Units i, 2, and 3
Inspection at Browns Ferry Site near Decatur, Alabama InsDecti on Conaucted:
November 1" - December 18 1989 Da. Si net
~A.
P
- erson, NRC Restart Coordina
.or Accomoanied LY nri S-.no:.
Res irien; In s" c:or
- 4. Bearden, Resioen-inspecwor K. Ivey, Resident Inspector J
Approvec bv:
S I s'vt I
~
'ect Ion I nie1 I.nspection.
- Programs, TVA Prospects Division D"
e Signed SUYiiv(ARY Scope:
This routine resident inspect,ion inclu'ded surveillance observations, licensed power indication, maintenance observation, operational safety verifica.ion, restart test
- program, and site management and organization.
0 Results:
The licensee' operating organization is s ill having problems with performing timely and adequate actions in response to control room alarms associated with off-normal condi ions.
This has resultec in the second viola:ion in less
-.han one year assocla ed with )css of la.ge quantities of potentially con amina-ed reactor grade wa-.er.
This viola.ion is described in paragraph 5.a.
In the llates; ei=.",:.
if the initial control room alarm had been adequate>y inv=s:ioa=ed in accordance with the Alarm
Response
Procedure the even=
coulio have been avoided..
The
.hree conditions i'nvolved in the deviation described in paragraph 5.b are further examples of single failure issues which continue to" be identified.
Other issues have been discussed, in Inspection Report 89-35.
The continuing discovery of single failure issues at t'ai.s late stage of preparation for restart is of concern to,the NRC.
A violation with two examples for failure to issue CA(Rs for TEs dispositioned as "repair", or "accept as -is" is identified in paragraph 6.
One example of this violation was significant, in that the licensee did no:
conduct an adequate performance
.est after installing new cooling units, although similar testing had been performed in tne pas:.
Site management has been unsuccessful in meeting the published milestone schedules.
Communications of these difficulties to the NRC could be improved as discussed in paragraph seven.
REPORT DETAILS Persons Contacted Licensee Employees:
- O. Zeringue, Site Director G. Campbell, Plant Manager N. Herrell, Plant Ooerations Manager
- J. Swindell, Plant Support Superintendent R. Smith; Proiect Engineer "J. Hutton, Operations Superintendent A. Sorrell, Maintenance Superintendent,
- M. Thomison, Acting Technical Support Superintendent G. Turner, Site equality Assurance Manager P. Carier,'ite Licensing Na'nager P. Salas, Compliance Supervisor J.
Corey, Site Radiological Control Superintendent R. Tut le. Site Security Manager Other licensee employees or contractors contac.ed included licensed reactor operators, auxiliary operators, craftsmen, technicians,
. and public safety. officers; and quality assurance,
- design, and engineering p'ersonnel.
NRC Attendees
~D. Carpenter, Site Manager
~C. Patterson, Restart Coordinator E. Christnot, Residen-.
Insoec-.o.
"M.'.Bearden.; Residen;,Inspector K. Ivey,'esident Inspector
~Attended exit interview Acronyms.used throughout this report are listed in the= last. paragraph.
Surveillance Observation (61726)
The inspectors observed and/or reviewed the SI procedures discussed below.
The inspections consisted of a review of the SIs for technical adequacy and conformance to TS, verification of test instrument calibration, observation of the conduct of the test, confirmation of proper removal from service and return to se'rvice of the
- system, and a
review of the test data.
The inspector also verified that limiting conditions for operation were me:, testing was accomplished by qualified
2 personnel, and the Sis were complet,ed at the required frequency.
The NRC inspectors ooserved/reviewed the following SI performance during this report period:
The inspector observed portions of O-SI-4.9.A'I.a(B),
Monthly Operabilitv or.
1B Diesel Genera-'or.
No deficiences were identified with he performance of this Si.
The inspector observed portions of O-SI-4.7.B2.d, S.andby Gas Treatmen.
System Operation
( 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> run).
This Si involved the simultaneous opera-ion of all three SBGT Trains.
Ho deficiences were identified with the performance of this SI.
The inspectors observed portions of the preparation and equipment setup associated'ith 0-SI-4 '.A3
~ a, Common Accident Signal Logic.
This infrequently performed test requires more extensive preparation and planning effort than most Sis and involves the accident logic for all three uni-s and all eight diesel generators.
The -est preparations were terminated on December 15,
- 1989, when the 1B CG was declared inoperable due to an inadverten.
dropp'ing of a
"Chem wipe" towel into "he 7
dav fuel tan);.
Tne towel was retrieved the fol-lowing day and preparations resumed.
Due to the time required to comple-e this test,
.esti ng wi 1 1 continue i nto the next reporting period.
Deficiences were not identified during the observed portions of this SI
~
t~o violations or deviations were identified in the Surveillance Observation area.
3.
Licensed Power Indication (42700)
Durino a review o' te procedures, the inspectors identif',ed a corice.ri in whicn the pla'n ould be allowed To ope aic above the noiilinai S power limit, within specified constraints.
General Operating Instruction, 2-GOI-100-1Ai Unit Startup From Cold Shutdown to Power Operation, Rev.
5, contains two not s on page 55 as follows:
( 1)
Do not operate such that the average thermal power for an eight hour shiit exceeds 3293 M'I'/T.
0 (2)
Do not exceed a thermal power of 3358 W0T under any conditions.
The inspector noted that in accordance with 2-GOI-100-1A, core thermal limits, including reactor
- power, are checI'ed at least three times during each shift.
- However, the limiting value specified on Illustration 1 of this procedure does not require an immediate power reduction if actual reactor power'as determined to be greater than 100',; power.
The inspector reviewed 2-SI-2.1, Core Performance
- Data, which 's
',n:ende" for use by the operator to verify that core thermal limits a, = witnin acceptance criteria.
Step 7.5 is used to document the ve, if',"a ion o=
thermal power.
A note at the beginning of the procedure s a:es
- ha a:
no time during reactor operation are core thermal limits to be ex cede".
F It is further stated x.ha if core thermal limits are determined to be in excess of limits action snail be taken within 15 minutes to return the reactor power to within acceptance criteria.
Although these statements were more conservative than those from the
- GOI, neither procedure contained a
specific requiremen tc
. immediate,ly
. initiate a
power reduction any time that core thermal power was known to be above 100."..
This conflicts with the requirements of the Unit 2 Facility Operating
- License, No.
DPR-52, which authorized the licensee to operate the facil.ity at steady state
, eactor core power not in excess of 3293 NMT.
Furthermore the bases for TS 1. 1.A. 1.
Fuel Cladding Integrity Safety L-imit for Thermal
- Power, states iha. tne licensed maximum power leve'l is 3293 tMT and.this represents the maximum steady state power and shall not knowingly be exceeded.
This issue is similar to a violation identified for the Seqouy'ah plant as documented in Inspection Report 327.
328/89-15.
The Seqouyah event occurred as
-'he resul:
of opera ing under a
Technical Specification interpre.ation which r ferenced ar, August 22,
- 1980, internal NRC memorandum asso"ia=ed wi-.n licensed oower level.
This memorandum was written to provid=
NRC i nspec-.ors wi' uniform guidance and c'.early s:a:es 'hat this gu dance is no-.
an NRC wide agreement.
Fu. ther discussions with the NRR technical staff indicates nat the memo assumed tha ihe licensee was con:roiii g
powe
~ 'excursions and -aking an ac-ive approach zo reduce the power below 100;". should inat value be exceeded.
The inspec.or reviewed th=
site copy of licensee Nuclear.Experience Review (N-"R-89-1035) transmittal dated October 13, 198"" (i 33891013802).
Alt'nough this NER referenced the Seqouyah NRC inspection report and violation, it was marked for information only.
The site's preliminary
- review, performed by a
licensee NER reviewer classified the item as generic and not applicable to the site, but routed fo'r information to the Opera:ions anQ Technical Supoo t Nanacers.
Ine N"-R did not require a
reply from any site organizations.
At the beginning of the reporting period, a
NRC inspector held meetings
- with members of the licensee management to discuss this concern During these meetings the licensee stated that they were aware of the Seqouyah
- event, that Browns Ferry STAs were aware of the site policy to never knowingly exceed 100.'o thermal
- power, a'nd that management had already planned to revise 2-GOI-100-lA to more clearly define their policy.
The licensee further stated that the current GOI limit of 3358 Yh/T was based on the 102,'; limit described in the referenced NRC memorandum.
Subsequent to the above meeting the inspector reviewed Revision 6 to 2-GOI-100-1A, which was issued on December 6,
1989.
The procedure had been revised to clarify the licensee's policy in this area.
Nore specifically the procedure now requires that the operator never knowingly allow power io exceed 3293 t~ih'T.
The licensee has taken adequate corrective actions to address
- h inspector s concerns in this area.
No violations or deviations were identified in the Licensed Power indication
.rea.
4.
Maintenance. Observation (62703)
Plant maintenance activi ies of selected safety-related systems and components w'ere observed/reviewed o ascertain that they were conducted in accordance with requirements.
The foliov ing items were considered durino this review:
the iimi-ing conditions for operations were me:;
activities were accomplished using approved procedures:
functional testina and/or calibrations were pe,formed prio" -o returning components or system to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; proper tagout clearance procedures were adnered to; TS were adhered to and radiological controls were implemented as required.
MRs were reviewed to determine
- he sta'.us of outstanding jobs and to assure tha. p,iority was assigned to 'safeiy-related eouipment maintenance which might'ffect plant safe:y.
The inspectors observed he maintenance act',vities listed below during this report period:
a
~
MR,898S50 was written o
wo; k on ihe "1A" DG right bank air dryer discharge cneck vai ve because the valve was st I cking open.
The inspec-.or observed tne work in the field and identified no deficiencies.
The inspector also walked down H080-89-1006, which isolated the sys-.em for work, anc identified no deficiencies.
MR S94761 was written wo disassemble,
- clean, inspect, and repair a
"1A" DG air star accumulator relief valve.
Problems with this valve were identified during the PMT for the MR documented above.
The NRC inspector observed the work in the -field, and the testin'g periorme" on the valve in the maintenance shop.
Deficiencies were no'dentified.
The inspec:or noted significant involvement by the system engineers and a
CIC inspector during the testing.
MR 1015031 was written to troubleshoot and repair the "1A" DG fuel transfer pump NZ because the pump would not achieve the required flow during survei 1'lance
.testing.
This work identified that the discharge check valve was not allowing the pump to prime itself causing flow problems.
This has been a recurring problem with the PZ pump.
No deficiencies were identified.
MR 898849 was writ en to remove the internals of the "lA" DG fuel transfer pump, f2 discharge check valve detailed above.
Due to recurring problems with the
- pump, TACF 80-89-001-018 was written to remove the check valve internals to determine if this will resolve the pump priming problems.
if this change is successful, a
DCN will be issued to remove the discharge check valves from all other Unit 1/2 DQ fuel transfer pumps.
The inspector reviewe" -ne MR and tne TACF and iden ified no deficiencies.
0
No viola.ions or deviatiions were identified
'in the Main.'enance Observation area.
5.
Operational Safety Verification (71707)
The inspectors were kept informed of the overall plant status and any significant safety ma:ters related to plant ope, a'.ions.
Daily discussions were held wi h plant management and various members of the plant ope. ating s aff.
The inspectors remade
",ou:ine visits zo ihe control rooms.
inspection observations included instrument
- readings, setpoints and recordings; status of operating sys-ems:
sta-us and alignments of emergency standby systems; onsite and offside emergency power sources available for automatic operation; purpose of temporary tags on equipment controls and switches; annunciator alarm status; adherence to procedures; adherence to limiting'onditions for operations:
nuclear instruments operabi li y:
tempo ary aitera ions in effec:;
dai Iy journals and logs; stack moni;or
- recorde,
- . aces; anc control room manning.
This inspection-ac iviiv also included numerous informa'I discussions with operato.
s and supervisors.
General plant tours we,e condu ted.
Portions of the turbine buildings, ea-h reactor
- buiwding, and genera'lant areas were visited.
Observations included valve positions and system alignment; snubber and hanger conditions; containment isolation alignments; instrument readings; housekeepin";
proper power supply and breaker alignments; radiation area controls:
tag con
~ oi=-
on eouipment; work aciivi-ies in progress; and radiation protection controls.
informal discussions were neld with selected plant personnel in their functional areas during these tours.
a.
Overflow of Spent Fuel Pool
-On Dece"aber 2,
19 9, he licensee informed the resident inspec-or of an incident involving the over flow of the Unit 2 Spent Fuel Pool.
At approximately 4:00 a.m.
on December 2,
- 1989, water was added to the Unit 2
Spent Fuel Storage Pool Skimmer Surge Tank.
The fill valve was inadvertently left open r'esulting in the spent fuel storage pool.water overflowing into the ven ilation ducts.
Water in turn leaked from the duct work seams onto reactor building equipment at elevations
- 593, 621, and 639.
The initial conditions were:
Unit 2
fuel pool cooling system/demineralizer in service; demineralizer bypass valves
- closed, and the fuel pool cooling water pump discharge pressure at 168 PSIG.
The spent fuel storage pool and reactor cavity water levels were equalized and the gates were removed.
The sequence of events and immediate corrective actions were:
The Unit 2 Reactor Building AUO was dispatched to the fue: cool cooling heat exchange area to open 2-FCV-78-66 to reduce tne fuel pool cooling pump discharae head to 130-150 PS!G pe; procedures 2-GOI-300-1 and 2-01-78.
Since the valve con-.rol
\\
was located in a contaminated
- area, the Unit 2 Turbine Building A>>.'as sent with the Reactor Building AUO who was to moni or the pump pressure gauge outside the contaminated area.
This operation utilized the local control switch for MOV 2-FCV-78-66.
The small amoun o,
change in pump discharge
- pressure, 169 to 150
- PSiG, woulo require only a
small valve movement.
in a
shor period of time the resul an: valve positioning caused the fuel pool cooling flow.o increase significantly.
This resulted in a
slimmer surge ank level reduction to the low-low
- setpoint, causing a
bypass of the SFP demineralizer and the fuel pool abnormal alarm to annunciate in the Unit 2 Control Room.
.To restore the fuel pool cooling system demineralizer to service, the Turbine Building AUO was dispatched to the refuel floor to add water to the skimmer surge tank via 2-HCV-78-532 until the low level alarm cleared.
The addition of water cleared the low-level condi ion in the skimmer surae tanl'nd allowed the demineralizer
-.o be re=urned
- o service.
The increase of the spen: fuel pool skimmer surge tank level as the deminera llzel was pIacec back in service caused the fuel pool abnormal alarm to annuncia o
again in the Unit 2 Control Room.
The local panel on elevation 621
.was checked io verify a high level in the surge
- tank, as expected.
At this time, the Control Room Unit 2 Operators increased r'eactor water cleanup blowdown flow to
-he Uni-c condenser
-o reduce this water level.
Based upon previous opera:ing expe
- ience, the high level alarm was expected
-.o clear in a'pproximateiy 30 to 45 minutes.
't approximately 4:50 a.m.,
the Unit 2 ASOS reported the local fuel pool level alarm was still alarmed high.
At 5: 10 a.m.,
tne Unit 2
ASOS reoorted water coming from the vent aucts in the Unit 2
Reac-or B"ilding a-eleva ion 621.
The unit operators verified that the core spray and RHR injection 'valves were fully closed and began looking for other makeup paths.
The Unit 2
ASOS checked the skimmer surge tank makeup valve 2-HCV-78-532 and found the valve hard to turn in the close direction.
He then opened the valve one half turn and proceeded to close the valve another four full turns shutting off makeup to the surge tank.
Reactor water cleanup blowdown was left.at 100 gallons pe'r minute to remove excess water in the system.
The event review determined that 2-HCV-78-532 was found to be
- binding, making it difficult-to operate.
This condition lead to the AUO believing the valve was fully closed.
The high level alarm was not adequately investigated per the alarm response procedure.
The initial response was correct but subsequent actions such as monitoring fuel pool level locally were not taken as reouired.
Tne failure to follow the alarm response procedure is ident'.fico
="s Violation 260/89-53-01, Failure to Respond in a
Timely f'.anne" to Off Normal Conditions.
The NRC inspector noted hat
<is
's a
repeat of the violation documented in NRC Repol 89 35 as Viola ion
- 259, 260, 296/89-35-04.
This violation applies to Uni: " only.
0
b.
Failure to Neet a Commitment to the NRC Oh October 3,
- 1989, the SOS and the STA-were informed of the failure to comply with 10 CFR 50.73 reporting requirements for two conditions identified in
'1986 and one condition identified in 1988 in which tne loss o<
a single main ba -.ery could place a unit in an unanaly.ed condition.
It was also determined that or ly orie of the three conditions was reportpd in a
- February, 1988 four hour ENS.
report and no LER was submitted.
The SOS then made a
4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> repor.
to. the NRC via the NS phone in accordance with 10 CFR 50.72 on all three conditions and :he fai lure to provide an LER.
The licensee ini<tia~ed an investigation into this ever,-
and identified the following:
1)
On July 23,
- 1986, a condition was identified to PORS where the lo'ss of any of the three main plant 2509 batteries could prevent a= least one of the 4809 shutdown boards on Unit 1 or Unit 2 from. load shedding, since
.he battery supo',ies power for breaI'er logic.
This was docuM>ented in SCR BFN NEB8607.
PORS dere. mined :hat tilere was not enough iniormatior, o deter'mine repor.abi 1'tv ard requested additional Information from DNE.
2)
On Decemoer '11,
- 1986, a condition was identified to PORS where the shutdown cooling primary containment isolation valves on ai l Thr22 Uf1 ts can<<a i l io auto<<<a ical ly c I ose l
on<
Unit bat:2 "v i s los:.
This was documen-.ed on SCR BFN NEB8613.
PORS determined znaT. there was not enougn info'rmaz,ion xo 'determine reportability and requested additional information from DNE.
3)
On January 29,
- 1988, CAQR BFP880067 was approved.
This CAQR supe. sedeo ne two SCRs anc i.ncluded a third condition wnere Tilt loss 0
he Unl 1
m<a I n ba.-ery could prevent al 1 load shedding from occurring.
4)
On February 5,
- 1988, PORS determined that the CAQR was reportabl'e<
a 4
hour non-emergency ENS report was
- made, and preparation was began on LER 259/88-04 addressing the CAQR concerns.
5) 6)
On Y<arch 8,
- 1988, the PORC rejected LER.88-04 questioning the reportability of the issue.
On April 1,
- 1988, a letter w'as sent to the NRC stating that LER 259/88-04 would not be submitted but that the concerns would be submitted in a
special report.
This special report was not submit ed to the NRC.
The failure to submit the special report constitutes a deviation from a
comm<ltmeni io the NRC (DEV 259,
- 260, 296/89-53-03).
On December 10, 1988, all corrective actions were comple:ed
-o resolve
the three conditions for Unit 2.
On September 21,
- 1989, three new CAgRs were issued to separate the three conditions by unit and reviewing these CAgRs led the licensee to.determine the conditions to be reportable.
'LER 89-25 was submitted on November 2,
- 1989, to report these conditions to the NRC.
The three conditions involved in this item are also further examples of single failure issues which continue to be identified.
Previous single fai lure issues were discussed in Inspection Report 89-35.
Each of these problems and the licensee's timely resolution of them are of concern to the NRC.
Accordingly, the response to the deviation should also address what programs are in place to identify single failure issues.
Unit Status All three units remained in an extended outage as part of the BFNP recovery plan.
Unit 1
and 3
are defueled with Unit 2 in cold shutdown with fuel loaded and the head removed.
The licensee had identified a series of milestones for returning groups of,- systems to service for restart.
Due to difficulty closing out engineering documentation and the continuing discovery of new
- issues, the licensee is planning to defuel Unit 2
in late December or early January.
The justification for, defueling is the difficulty of working around divisional outages in a timely manner.
The current milestones will then become meaningless requiring a
new schedule'.
The remaining'ork activities will be worked together in bulk fashion.
One violation and one deviation were identified in the Operational Safety Verification Area.
Restart Test Program (99030B)
The inspector maintained cognizance of ongoing restart test activities, and monitored particular activities in detail as appropriate.
Speci,fic inspection observations are discussed in paragraphs below.
Review of Testing Activities.
The inspector reviewed four completed and vaulted RTP test procedures; 2-BFN-RTP-031A, Control Bay Heating Ventilation and Air Conditioning; RTP-031B, Control Bay HVAC; RTP-074, Residual Heat Removal System; and RTP-099, Reactor Protective System.
The inspector noted the following:
2-BFN-RTP-031A, Control Bay Heating Ventilating and Air Conditioning System.
The RTP test group documented a total of ten TEs as a result of the performance of this procedure.
TE-07, which documented the fact that the Unit 1 and 2 Control Bay chill-water flows failed to meet acceptance
- criteria, was
9 reviewed and the inspector noted tha. this significant test defic',ency did not result in tne generation of a CAQR.
Further review of the completed procedure indicated that TE-07 was reviewed by the RTP group using criteria established in SDSP
- 3. 13,'orrective Actions.
Section 6.6, CAQR Determination, subsection D s;ates:
Test deficiencies
- which, by evaluation, indicate that the item does no comply with the license de'sign basis or will affec. plant -echnical specifica ions shall be placed on a
CAQR i; "accep-.-as-is" or "repair" actions are being considered.
At the time of the inspection, SDSP
- 3. 12, CSSC and non-CSSC
- Listing, attachment B,
Critical Structures System and Components, section 6.0, Main Control
- Bay, subsection 6.2, Conirnl Bay and Shu-oown Board Room Air-Conditioning systems lis ed air handling uni;s and pumps.
The iicensee's decision not -o use a
CAQR :o document his deficiency does not appear to be consisten=
with he plan-.
me hodology for iden ifying significan de iclencles.
Additional review of this item indicated that
!E-10 was added to the procedure after RTP Tes.
resuj:s we;
=- approved.
T=-10 indica ed that TE-07 was beino closed'ut by the use of a
Temporary Alteration, TACF 0-88-002-031.
This use of a TACF to closeout a significant TD is a
, epai.
ac:ion ana a
CAQR should have been in',-iated.
This is a violation of 10 CFR 50, Appendix B Criterion
- KV1, Corrective Action as implemeted by NQAM, Part 1,
Section
- 2. 16, Corrective Action; and SDSP
- 3. 13, Corrective Actions.
This is identi'fied as the 'first example of VIO 260/89-53-02, Failure to 1niYiate CAQRs fo; 0',spnsi-.ion of TFs.
TVA managemen:
did no agree tha-
-.nis was a
viola
',o'n since they Delieved the temporary alteration was not a repair.
Z-BFN-RTP-031B, Control Bay HVAC.
The RTP test group documented a total of 28 TEs as a result of the performance of this procedure.
The MRC inspector noted TFs 24, 25, 26,
'nd 28 were left open.
Closeout of these TEs was dependant on modifications being completed, maintenance or the performance of technical instructions.
TE-27, which was considered
- closed, was reviewed and referenced a post modification test, PMT 161,-
Shutdown Board Room HVAC Systems, as a method for closing the TE.
A review oi PMT 161 indicated that a test deficiency, TD-5, was documented and addressed the fact that flow bala'nce criteria could not be met.
The TE-27 indicated tha based on interim approval of TO-5, the TE was considered closed.
TO-5 was dispositioned by engineering as acceptable using he flow balance da-.a obtained.
This approach seemed reasonable since the flow balance data was near the acceptable values anc was evaluated by enginee.ing.
10
- Shutdowr, Board Room Cooling Units - Post Modification Test As part of the review for this item the inspector reviewed the licensee's closure package for IFI 259, 260, 296/84-38-02, Shutdown Board Room A/C Tes..
This was left open in IR 259,
- 260, 296/88-05 pending successful completion of testing each unit.
New units were being installed for Unit 2 per ECN P0956.
The purpose of this ECN was to upgrade the Emergency Ventilation System for Shutdown Board
, Rooms C
L D.
The licensee's engineering effort indicated that the original Emergency Ven-ilation System would not meet
.he present heat removal requiremenis of the iwo Shutdown Board Rooms durino an emergency situation.
PMT-161 was to be performed after installation.
The inspector reviewed PMT-161 and noted the acceptance criteria for the cooling capacity were not met.
The cooling units had tripped prior io taking ne test daia r'equired for the cooling. capacity calculation.
Test Excep.ion EN-8 was wriiten and dispositioned as acceptable
>>i thout testing because the test would requi re additional hea-'oad to be added ir. the room.
in the past, the units were tested per T:-S1, Shutdo>>'n Board Room Fmergency Cooling System Performance Check.
Included in Ti-S1 was a
cooling capaciiy calculation and acceptance criteria in units.of BTUs per hour.
included in.PMT-161 was also a cooling capacity calculation using ihe same formula to calculate a value in BTUs per hour.
The acceptance criteria for the capacity was given in procedure step 6.4.
The test
'xception in quesiion w
s taken against this value.
Failure to run tne test.
was not-identified as a iest deficiency and a
CA(}R was not issued.
Additional review of this item by the NRC inspector indicated that durirc PYiT-16'll tes-,img for ECN P0956
>>as completed.
Th'.s was documented
'in a
memo RIHS B2289 0321 012 from the 'Projec Engineer to the Plant Yianager dated March 21, 1989.
The inspector also has concerns with the A/C because of an existing 10 CFR Part 21 report.
On September 20,
- 1989, the licensee no ified the NRC by a
Part 21 report of a defect with the two air-conditioning units provided by Ellis 8
Watts.
The defect was identified as a result of an audit of the Ellis 8 Watts quality assurance practices and subsequent field investigations that led to an evaluation of a deviation from a
TVA procurement contract.
TVA initiated a
CA(}R report in July
- 1989, describing the use of undocumented
. electrical components and cabling in these air-condi tioning units and inadequate environmental qualification documents.
On December 18,
- 1989, prior to the exit meeting the license=
provided the inspector Ellis K Watts performance test reoor:
aa:a which
>>'as used by engineering to determine that testing was no:
required.
The data was taken in August 1987.
The PMT
>>as performed in November 1988.
The inspector did not see the correlation since the PMT was written after the performance es.
11 report.
The Ellis & Matzs data looked, like a bench test tha. would normal l5 be expected
. or ne>>
equi pmen.
supplied by a
vendor.
The inspector noted that for the "A" train there were several tests which were indicated as
- passing, but the test data was outside the'llowable range.
The ai " flow ra e
and velocity pressure da.a were indicated as not applicable.
The water pressure drop was 49 psid, but the maximum allowable w'as 6.5.
The inlet air temperature was.
73.4 degrees F and he outlet air temperature was 58.0 degrees F.
The test report s a:ed
.naz the outlet air zemperature must be at leas-:
=30 degrees, i brio>> the inle: air temperature.
bui in this zest the tempera.ure difference was only 15.4 degrees.
The test report for the "B" train did not contain any of these problems.
The inspector provioed the Site Prc.iecz Eng neer these concerns at t¹ exit meeting.
The inspector was concerned that with the surrounding he units, tne existing Par-21 vendor tesz data, and the ability zo test ihe units should be given a cooling capacity -es-.
hi storical problems repor:,
queszionabie units in the pas:.
'he The inspeczor discussed with the license that testing had
- beer, consiie; ed compie
.e wnen a
signi ficanz TO was documenzed api a
signif cant zes
>>'as noz ierformed, and.ha-'he equipment would be accepzed "as is".
ho CA(jR was initiaz.ed per plant procedure to document that a significant test was not be performed.
This is the secona exam@le o;
PIG
>60t89-5 -02.
The licensee management stated znaz
=-
CAOR was no: requirea since an engin ering evaluation concluded
- zhaz, a performance tesz was not required.
RTP Review of TFs Subseauent zo tne idenzif,cation o
=he Resident Inspec.ors concerns tne licensee il it ia 2G an aczion plan zo review and address he concerns..
In a letter dated September 26,
- 1989, the licensee outlined activities involving the following:
- RTP, TEs related to hardware issues were review(ed for adequate closure; the RTP program instructions and program performance history
>>ere reviewed against the requirements for generating CAgRs;
'and the issue regarding signi ficant recommendations made by the RTP Test Directors
>>as evaluated.
This in turn resulted in an extensive review of the RTP TEs and the addressing of NRC concerns.
In a letter addressed to the BFP Licensing for the RTP group this extensive review was documented at SLT 890934003.
This review indicated a total of nine concerns were addressed with the following information:
Concern number one addressed the reluctance to initiate CAgRs for significant TEs; concern number two addressed the process of closina out and vaulting completed RTP test proced res with open TEs:
concern numbers three thru eight addresse" spec',f':c NRC concerns identified in various h'RC reports and con"e;n
.". '=er nine addressed the recommendations made by the RTP Tesz Di -. ec;o:
-=.
The NRC i..spec or reviewed SLT 890934003 and with the exec>iion of.
concern number one, determined -hat:
0
12 The licensee adequately reviewed the
The categorizing of TEs into hardware and non-hardware deficiencies was adequa e.
The licensee is'sued PRDs to address programatic deficiencies during the review.
The NRC inspec-or documen-ed in Repor. 89-38, URI 259, 260, 296/89-38-03, Possible Fail re to Follow the BFN Program ior Identifying and Closing Significant TEs and to Control Procedure Changes.
This URI is closed based on the review o;
RTP T;s and the opening of viola:ion 260/89-53-.02.
One. violation was identified in the Restart Test Program area.
7.
Site management and Organization (36301,
- 36800, 40700)
Site management nas
- beer, unable
-.o meet the published milestone schedule for returning sys ems to service.
During the conduct of an NR" te'am-inspection concerning the c sian, construction and operational adequacy of =ne CS Sys em, the licensee announced 01ans to GeTUel Un'ne of tne reasons given for one decision to defuel was that auring tne engineering paperwork closure for the CS
- system, new work items were discove lcd, ne mos7.
significan of which w"s that environmen.al qualification of approxima;ely 30G electr',cai cables could not be demonstrated.
The licensee elected to replace these cables.
Two otner reasons given for the decision to defuel were; the need to establish inventory control of SNM, and less restrictive requirements on Divisional outages to complete other engineering/modification work.
Site Management ho-d aopa. en:iy under-es imaged the aifficui-.y of the closure process and has rc-.urnec t'o a
discovery s-.a-.e.
The licensee s
managemen:
communication of these problems to the
- NRC, NRC resident staff, and team inspections was not always open and timely.
8.
Exit I'nterview (30703)
The inspection scope and findings were summarized on December 18, 1989 with those persons indicated in paragraph 1
above.
The inspectors described the areas inspec'ed and discussed in detail the inspection findings listed below.
The licensee did not, identify as proprietary any of the material provided to or reviewed by the inspectors during this inspection.
The Site Director stated that based on the information presently available, TVA disagreed with violation 260/89-53-02, Failure
. to Initi'ate CAgRs for Disposit,ion of TEs.
Item 260/89-53-01 Description Violation, Failure io Hanner to Off-Normal 5.a.
Respond
':; a: imely Conditions, paragraph
0
260/89-53-02 13 Viola ion, Failure to 'Initiate CAQRs For Disposition o
- TEs, paragraph 6.b.
- 259, 260, 296/89-53-03 Deviation, Failure To 'Submit a Special Report In Accoldance Mi h
a Licensee Commitment, paragraph 5.b.
9.
Acronyms ACU ASOS AUO BFNP CAQR CFR CS CSSC DCN DEV DG DN=
ECN ENS GOI He HVAC LER YiOV MR Ma-.'on, 6 Air Condit Licensee Even=
Repo. t italo-.or Operated Valve Main'enance Request Megawa--t Thernlal Nuclear Experience Review Nucl a>> Oualiiy Assura;Ice Manual Nuclear Reactor Regulation Operating Instruc ion Post Yiod:fication Test Purchase Order Plant Operations Review Committee Plant Operation Review Staff Problem Reporting Document Pounds Square Inch Gauge Qua'lity Control Revision Residual Heat Removal Restart Test Program Standby Gas Treatment System Significance Condition Report Site Directol Standard Practice Spent Fuel Pool Surveillance Ins:. uc-.ion Special Nuclear Yiaterial, Shiit Operations Supervisor
~ t l ecnni cal AdY1 so
!-.-novary Al-.era:ion Chanoe Fo 8 Te~t Deficiency Test Exception Technical Specificatior, Tennessee Valley Authority Unresolved Item Viola;ion