ML18033B523
| ML18033B523 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/16/1990 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9010250270 | |
| Download: ML18033B523 (14) | |
Text
ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
SSION NBR:9010250270 DOC.DATE: 90/10/16 NOTARIZED: NO CIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 50-296 Browns Ferry Nuclear Power Station', Unit 3, Tennessee AUTH.NAME AUTHOR AFFILIATION MEDFORD,M.O.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 05000259 05000260 05000296 D
/
05000259 05000260 05000296
SUBJECT:
Responds to NRC 900917 ltr re violations noted in Insp Repts 50-259/90-25,50-260/90-25
& 50-296/90-25.
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,S.
BLACK 1 Copy each to: S.Black,B.WILSON 1 Copy each to:
S.
Black,B.WILSON INTERNAL:
RECIPIENT ID CODE/NAME HEBDON,F ACRS AEOD/DEIIB DEDRO NRR SHANKMAN,S NRR/DREP/PEPB9D NRR/DST/DIR SE2 NUDOCS-ABSTRACT OGC/HDS2 RGN2 FILE 01 COPIES LTTR ENCL 1
1 2
2 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
REG FIL 02 RECIPIENT ID CODE/NAME ROSS,T.
AEOD AEOD/TPAD NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DRIS/DIR NRR/PMAS/ILRB12 COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 D
EXTERNAL: NRC PDR NOTES' 1
5 5
NSIC 1
1 D
NOTE TO ALL"RIDS" RECIPIENTS:
D D
PI.EASE HELP US TO REDUCE iVASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOil Pl-37 (EXT. 20079) TO ELIiIINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUilENTS YOU DON'T NEED!
TAL NUMBER OF COPIES REQUIRED:
LTTR 27 ENCL 27
<<(
TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 6N 38A Lookout Place ON 16 1SSQ 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 IiVSPECTION REPORT NOS. 50-259/90-25, 50-260/90-25, AND 50-296/90-25
RESPONSE
TO VIOLATIONS This letter provides TVA's response to the letter from B. A. Wilson to 0.
D. Kingsley, Jr.,
dated September 17, 1990, which transmitted the subject report.
The'eport cited TVA with two violations.
The first violation involved a failure to have an adequate fire protection surveillance instruction.
The second was for failure to follow a workplan to protect emergency electrical equipment from water intrusion.
TVA admits to both violations.
Enclosure 1 provides TVA's response to the violations.
A summary list of commitments is provided in Enclosure 2.
Please refer any questions concerning this submittal to Patrick P. Carier, BFN, Site Licensing, (205) 729-3570.
Very truly yours, TENNESSEE VALLEY AUTHORITY Mark 0. Medford, Vice President Nuclear Assurance, Licensing and Fuels Enclosures cc:
See page 2
~Y(o An Equal Opportunity Employer
0
cc (Enclosures):
Ms. S.
C. Black, Deputy Director Project Directorate II-4 U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike, Rockville, Maryland 20852 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637
- Athens, Alabama 35609-2000 Mr. Thierry M. Ross, Project Manager U. S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
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e ENCLOSURE 1
RFPLY TO A NOTICE OF VIOLATION BROWMS FERRY NUCLEAR PLANT NRC INSPECTION REPORT NOS. 50-259/
90-25, 50-260/90-25 AND 50-296/90-25 During the Nuclear Regulatory Commission (NRC) inspection conducted on July 21 August 17, 1990 two violations of NRC requirements were identified.
The first violation involved a failure to have an adequate fire protection surveillance instruction (SI).
The second violation was for failure to follow a workplan to protect emergency electrical equipment from water intrusion.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (1990), the violations are listed below:
Technical Specification (TS) Section 6.8.1, Procedures, requires that written procedures be established, implemented and maintained covering surveillance and test activities of safety-related equipment.
Contrary to the above, surveillance requirements 4.11.B.1.f(4) had not been performed on the high pressure fire protection system since incorporation of TS amendment number 159 dated December 27, 1988.
Once every 18 months, the system pressure is required to be verified greater than or equal to 120 psig after sequential fire pump starts.
SI O-SI-4.11.B.l.f, Simulated Automatic and Hanual Actuation of the High Pressure Fire Pump System, which had been performed on January 6,
1990 did not verify the 120 psig requirement or refer to a calibration procedure for pressure switch PS-26-44 that would include the requirement.
The pressure switch'as found to be calibrated with a 100 psig setpoint.
This is a Severity Level IV violation (Supplement I) applicable to all three units.
TVA's Res onse 1.
Admission or Denial of the Violation TVA admits the violation.
2.
Reason for the Violation This violation has been attributed to personnel error during the preparation and approval of SI O-SI-4.11.B.l.f.
During the preparation of the SI, the requirement to verify that after an initial high pressure fire pump actuation each subsequent high pressure fire pump starts sequentially to maintain the high pressure fire protection system pressure greater than or equal to 120 psig was not included.
The surveillance instruction did not reference any calibration procedure to ensure the pressure switch was being calibrated to meet TSs.
A contributing factor in this violation was the setpoint for pressure switch PS-26-44.
This pressure switch was being calibrated at 100 psig and not 120 psig, as required by TSs.
An Engineering Change Notice which included a
change to the pressure switch setpoint was closed with the pressure switch setpoint at 100 psig and not the 120 psig as required by TSs.
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The reason this personnel error took place can only be presumed.
The personnel involved were contract personnel and are no longer employed by TVA.
This error was discovered by TVA personnel during a required procedure review.
3.
Corrective Ste s Mhich Have Been Taken and Results Achieved In order to comply with TSs, plant maintenance personnel recalibrated pressure switch PS-26-44 to 120 psig.
Of the 44 fire protection related SIs, 35 have undergone a comprehensive review as part of the post-SI performance cognizant engineer review.
To date, this is the only TS implementation pxoblem that has been identified.
Additionally, all the procedures undergo a biannual review which requires a
review of TS implementation.
Since 80 percent of the SIs have been reviewed and the remainder will also be reviewed as part of the biannual review, TVA considers that there is reasonable assurance that the fire protection TS has been adequately implemented.
~
'uring the time that this surveillance instruction was being prepared for issue the fire protection personnel, engineering and fire fighters were being administratively controlled by one manager.
- Today, the fire protection personnel are divided into two groups.
The fire fighters are administratively controlled by the operations manager while engineering support have been placed under the technical support manager.
e Corrective Ste s Mhich Will be Taken to Avoid Further Violations The Engineering Change Notice (P210), in which the pressure set point was
. changed from 120 psig to 100 psig, will be reviewed and corrected so the setpoint requirement for the pressure switch agree with TS requirement.
SI O-SI-4.11.B.l.f will be revised so it fulfills the requirements of TSs.
5.
Date Mhen Full Com liance Mill be Achieved Engineering Change Notice P210 will be reviewed and revised as necessary.
This will be completed by November 30, 1990.
SI 0-SI 4.11.B.l.f will be revised by November 30, 1990.
Violation B 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings,"
requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and be accomplished in accordance with the instructions, procedures, or drawings.
TVA Nuclear Quality Assurance
- Plan, TVA-NQA-PLN89A, Section 6.1, establishes the requirements for control and use of procedures and instructions.
TVA work plan 2396-90 required that watertight covers be placed over penetrations t
in the roof of the unit 1/2 diesel generator building where conduit had not been installed and grouted.
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Contrary to the above, on July 23, 1990, during the implemen'tation of the workplan, the penetrations made in the unit 1/2 emergency diesel generator building roof were not covered with watertight covers.
Water entered the building through the open penetrations and wetted the "B" and "C" emergency diesels and controls and the "C" emergency diesel batteries, which resulted in the "C" diesel generator being placed in an inoperable status.
Water had previously entered the diesel generator building on July ll, 1990.
This is a Severity Level IV violation (Supplement I) applicable to units 1 and 2.
TVA's Res onse 1.
Admission or Denial of the Violation TVA admits the violation.
R 2.
Reason for the Violation This violation was attributed to personnel error for a failure to provide a watertight cover, as required by the workplan, over an open penetration prior to installation of a conduit penetration.
On July 11,
- 1990, the first time a leak was noted, a temporary plywood cover had been installed over an open penetration, but because the roof drains were clogged the plywood cover floated off of the penetration, thus allowing water to enter the diesel generator building.
The corrective action taken by modifications was to clear the roof drains and seal the plywood to the roof.
On July 23, 1990, modifications personnel were working on a different penetration in the same workplan.
Because the roof drains were working properly, the modifications personnel placed a plywood cover over the penetration;
- however, they did not seal the plywood to the roof.
A short downpour of rain came and dead mayflies clogged the'rain screens allowing water to enter the diesel generator building.
One of the six clogged drain screens was subsequently removed and all of the water on the diesel generator building roof drained off.
3.
Corrective Ste s Which Have Been Taken and Results Achieve After the first incident on July 11, 1990 a water-tight cover was placed over the penetration being worked.
The six four-inch roof drains in the diesel generator building roof were cleaned and verified clear.
Workplan 2396-90 is completed, there are no open penetrations in the diesel generator building roof.
II 4.
Corrective Ste s Which Will be Taken to Avoid Further Violations No further corrective steps are required.
t 5.
Date When Full Com liance Will be Achieved Full compliance has been achieved.
ENCLOSURE 2
LIST OF COMMITMENTS NRC INSPECTION REPORT NOS. 50-259/
90-25, 50-260/90-25 and 50-296/90-25 Letter From B. A. Wilson to 0.
D. Kinglsey, Jr.
dated April 17, 1990 1.. Engineering Change Notice P210 will be reviewed and changed as necessary to correct the pressure switch setpoint.
This will be completed by November 30, 1990.
2.
Surveillance Instruction O-SI-4.11.B.l.f will be revised so that it fulfills technical specifications.
This will be completed by November 30, 1990.
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