ML18036A845

Provides Response to 920803 Ltr Re Violations Noted in Insps Repts 50-259/92-24,05-260/92-24 & 50-296/92-24.Corrective Actions:Mod Criteria for Corrosion Monitors Dcn & Valve Data Sheet Containing Erroneous Info Corrected

ML18036A845
Person / Time
Site:	Browns Ferry
Issue date:	08/31/1992
From:	Zeringue O TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9209040100
Download: ML18036A845 (10)

Text

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~ . I ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEN (RIDS)

CESSION .NBR: 9209040100 DOC. DATE: 92/08/31 NOTARIZED: NO DOCKET 0 CIL: 50-259'roens Ferry Nuclear Poeer Station, Unit 1, Tennessee 05000259 50-260 Broens FerrM Nuclear Power Stationi Unit 2i Tennessee 05000260 50-296 Broens Ferry Nuclear Power Stationi Unit 3i Tennessee 05000296 AUTH. NAME AUTHOR AFFILIATION ZERINGUEI O. J. Tennessee Valley Authority RECIP. NAME RECIPIENT AFFILIATION R Document Control Branch (Document Control Desk)

SUBJECT:

Provides respo'nse to 920803 ltr re violations noted fn Insps Rep ts 50-259/92-24'5-260/92-24 5 50-296/'P2-24. Corr ec tive actions:mod criteria for corrosion monitors DCN h valve data sheet conta'ining erroneous info corrected.

DISTRIBUTION CODE:

TITLE: General IEDID COPIES RECEIVED: LTR (50 Dkt)-Insp Rept/Notice of I

ENCL Violation

+ SIZE:

Response

NOTES: A REC IP IENT COPIES REC IP IENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL HEBDONI F 1 1 ROSSI T. 1 1 t

MILLIAMSIJ. 1 1 INTERNAL: ACRB 2 2 AEOD 1 1 AEOD/DEIB 2 2 AEOD/DSP/TPAB 1 1

• EOD/TTC 1 1 DEDRO 1 1 NRR MORISSEAUI D 1 1 NRR/DLPQ/LHFBPT 1 1 NRR/DLPG/LPEB10 1 1 NRR/DOEA/OEAB 1 1 NRR/DREP/PEPBVH 1 1 NRR/PMAS/ILRB12 1 NUDOCB-ABSTRACT 1 1 .E 1 OGC/HDS3 1 1 REG FILE 02 1 1 RGN2 F ILE 01 1 1 EXTERNAL: EGZcG/BRYCEI J. H. 1 1 NRC PDR 1 1 NSIC 1 1 NOTE TO ALL "RIDS RECIPIENTS PLEASE HELI" US TO R" DUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.

ROOM pi-".7 (EXT. 504-2065) TO ELIMIINATEYOUR NAME FROM DISTRIBUTION LiSTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

0' 0 Tennessee Valley Authority, Post Office Box 2000, Decatur,'Alabama 35609 O. J. 'Ike'eringue Vice President, Browns Ferry Operatfons AUG 3i >99Z U.S. Nuclear Regulatory Commission ATTN: Document Control'Desk Washington, D.C. 20555 Gentlemen:

In the Matter of Docket Nos. 50-259 Tennessee Valley Authority 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) NRC INSPECTION REPORT 50-259, 260, 296/92-24 REPLY TO A NOTICE OF VIOLATION (NOV)

This letter provides TVA's reply to the NOV transmitted by letter from B. A. Wilson'ated August 3, 1992. In this letter, NRC cited TVA with a violation for failure to use the correct hydrostatic test pressures to adequately test component welds of a safety system.

TVA shares the Staff's concern that a system was tested improperly.

However, TVA notes that although one loop of the Residual Heat Removal system was conservatively declared inoperable, the system was subse'quently confirmed capable of performing its design function.

Furthermore, TVA is encouraged that this condition was discovered because plant personnel had a questioning attitude during the performance of their routine activities. In this case, a supervisor had identifie'd a problem during the processing of a routine workplan change; In response to that discovery, an engineer initiated a review of other workplans for similar errors. It was during that expanded review that the condition cited in the violation was identified.

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U.S. Nuclear Regulatory Commission NB 31 1992 TVA's "Reply to the Notice of Violation" (10 CFR 2.201) is contained in the enclosure to this letter. If you have any questions regarding this response, please telephone Raul R. Baron at (205) 729-7566.

Sincerely, J. Zering e Enclosure cc (Enclosure):

. NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611 Mr. Thierry M. Ross, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852'r.

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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'0 ENCLOSURE Tennessee Valley Authority Browns Ferry Nuclear Plant (BFN)

Reply to Notice of Violation (NOV)

Inspection Report Number 2-24 "During the Nuclear Regulatory Commission (NRC) inspection conducted on June 17-July 17, 1992, a violation of NRC requirements was identified.

In accordance with the 'General Statement of Policy and Procedure for NRC Enforcement Actions,'0 CFR Part 2, Appendix C, the violation is listed below:

10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances, and shall be accomplished in accordance with these instructions, procedures, or drawings.

Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Contrary to the above these requirements were ~ot met in that hydrostatic test pressures used after installation of corrosion monitors in the residual heat removal service water (RHRSW) system were incorrect. The RHRSW heat exchanger piping components were tested to 185 psi instead of the actual design pressure of 450 psi. This was discovered by the licensee on June 19, 1992, and a limiting condition for operation was entered that resulted in Loop II Containment Cooling Mode of the RHR System being inoperable. This condition had existed undetected for 17 days. During that time other activities associated with redundant equipment resulted in plant conditions that required the plant to be placed in a cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

This is an example of a Severity Level IV Violation (Supplement I) applicable to all three units."

0 This violation was a result of ineffective procedural contxols. for hydrostatic testing. Hydrostatic testing instruction, Modification Addition Instruction (MAI) 4.7A, instructed the user to calculate test pressure based on the design pressure of the RHRSW piping, but did not stipulate where (or from what document) to obtain the design pressure. This latitude resulted in an error made at the design development stage propagating through the design process to installation.

In January 1'991, TVA initiated a workplan to install corrosion monitors at various locations in the RHRSW system. The installation was completed and tested on June 4, 1992. This

,installation, which included welding sockolets and acc'ess fittings'f the monitors in place, was hydrostatic tested at the valves at a design pressure of 185 psig. During monitors'ampling subsequent review on a corxosion monitors workplan change, TVA discovered that the system should have been hydrostatically tested at a pressure of 450 psig.'hat is, the corrosion monitor sampling valves were underpressurized when tested.

This event occurred when the engineering personnel that generated the RHRSW modification criteria for the corrosion monitors design

.change notice (DON) incorrectly listed the system mechanical requirement (i.e., 185 psig instead of 450 psig). This requirement was then transferred to the valve -data sheet as the design pressure. This error led the modification personnel responsible for workplan development to improperly use the erroneous valve data sheet (as opposed to using the latest available configuration control diagram) to calculate the test pressure.

The Staff noted in the NOV that during the time of this event other activities associated with redundant equipment resulted in plant conditions which required the plant to be placed in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. TVA recognizes that the RHRSW system, as tested, did not- conform to all aspects of the current licensing basis. However, the sockolets and access fittings of the corrosion monitors were visually inspected and penetrant tested, and the system was successfully retested at the corxect design pressuxe.

Accordingly, plant conditions did not exist which would have required the plant to be placed in a cold shutdown condition.

t v t k The immediate corrective steps were to retest the corrosion monitor valves at the correct design pressure of 450 psig, (minimum test pressure 562.5 psig, maximum test pressure 596.25 psig). This retest was successfully performed on June 20, 1992.

NAI 4.7A has been revised to clarify which source document is required to determine system design pressures for hydrostatic testing. Also, the modification criteria for the corrosion monitors DCN and the valve data sheet containing the erroneous information were corrected.

tv t t k t th Xia~tma Both the appropriate engineering and modification personnel have reviewed the incident investigation report for this event. Also, the modifications personnel responsible for using the incorrect test pressure document in the development of the workplan have been counselled.

B v TVA believes that full compliance has been achieved.

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