ML18037A405
| ML18037A405 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/06/1993 |
| From: | Zeringue O TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9308110076 | |
| Download: ML18037A405 (20) | |
Text
ACCELERATED DOCUMENT DISTRIBUTIONSYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
"CCESSION NBR:9308110076 DOC.DATE: 93/08/06 NOTARIZED:
NO DOCKET CIL: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 AFFILIATION ZERINGUE,O.J.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 930323 ltr re violation
& deviation noted in Insp Repts 50-259/93-23,50-260/93-23
& 50-296/93-23.
Corrective actions:identified valves placed in closed position
& handles removed from valves.
DISTRIBUTION CODE:
IE01D COP1ES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
RECIPIENT ID CODE/NAME PD2-4-PD WILLIAMS,J.
ACRS AEOD/DSP/ROAB AEOD/TTC NRR/DORS/OEAB NRR/DRIL/RPEB NRR/PMAS/ILPB1 NUDOCS-ABSTRACT OGC/HDS3 RES/HFB EXTERNAL: EG&G/BRYCE,J.H.
NSIC COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME ROSS,T.
AEOD/DEIB AEOD/DSP/TPAB DEDRO NRR/DRCH/HHFB NRR/DRSS/PEPB NRR/PMAS/ILPB2 O>DX-E IL 02 GN2 FILE 01 NRC PDR COPIES LTTR ENCL 1
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1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 25 ENCL
-25
Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609.2000 O. J. "Ike" Zeringue Vice President. Browns Ferry Nuclear Pfan; AUG 0 6 1993 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) - NRC INSPECTION REPORT 50 259I 50 260I 50 296/93 23 REPLY TO NOTICE OF VIOLATION (NOV)
AND NOTICE OF DEVIATION (DEV)
This letter provides TVA's reply to.the NOV and the DEV transmitted by letter from R. V. Crlenjak to M.
O. Medford dated March 23, 1993.
In this letter, NRC cited TVA with a NOV consisting of three examples for a failure to follow procedures and identified a DEV consisting of two examples related to the issuance of configuration control drawings.
Enclosure 1 to this letter provides TVA's "Reply to the Notice of Violation" (10 CFR 2.201).
Enclosure 2 to this letter provides TVA's reply to the Notice of Deviation.
A listing of commitments made by this letter is provided in Enclosure 3.
If you have any questions regarding this reply, please telephone Pedro Salas at (205) 729-2636.
Sine rely, Q((lP(
Zerin ue Enclosures cc:
See page 2
100082 S'30811007h 930806 PDR ADOCK 05000259 PDR
U.S. Nuclear Regulatory Commission AUG 0 6 1993 Enclosures cc (Enclosures):
Mr. R. V. Crlenjak, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 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
(
ENCLOSURE 1
Tennessee Valley Authority Browns Ferry Nuclear Plant (BFN)
Reply to Notice of Violation (NOV)
Inspection Report Number 50-259 260 296 93-23 RESTATEMENT OF VXOLATXON "During the Nuclear Regulatory Commission (NRC) inspection conducted on May 15 June 18,
- 1993, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
Technical Specification 6.8.1, Procedures; requires that written procedures shall be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Appendix A of Regulatory Guide 1.33 includes procedures for Startup, Operation, and
- Shutdown, of Safety-Related
- systems, including the Control Room Heating and Ventilation System.
Operating Instruction, O-OI-31, Control Bay And Off-Gas Treatment Building Air Conditioning System, valve lineup checklist, is the controlling document which lists the required configuration for the Control Room Emergency Ventilation equipment.
Contrary to the above, on May 24, 1993, with the system required operable, these configuration requirements of 0-OI-31 were not met for the following three examples:
1 ~
2 ~
Drain valves O-DRV-31-7361, and 0-DRV-31-7367 are required to be in the closed position.
Contrary to'his on May 24, 1993, the inspector identified the valves were in the open position.
Operating Instruction, O-OI-31, Control Bay And Off-Gas Treatment Building Air Conditioning System, valve lineup checklist, requires dampers 0-DMP 7215 and 0-DMP-31-7216 to be throttled such that the damper handle is positioned over the red mark painted on the duct work.
On May 24, 1993, the inspector identified this verification had been performed and independently verified even though no red mark existed for this purpose.
3.
0-OI-31 valve lineup checklist,. did not, include position verification of'drain valve O-DRV-31-7360.
This is a Severity Level IV Violation (Supplement I) applicable to all three Units."
REPLY TO VXOLATXON Reason for Violation A.
B.
Example 1 - Mispositioned Drain Valves TVA considers that this example is the result of the configuration of the Control Room Emergency Ventilation System (CREVS) control panel.
Specifically, the capped drain lines and the drain valves are located in such a position that access into the control panel resulted in the handles of the drain valves being placed in the open position.
Since the lines were capped, the mispositioning of the drain valves would not have resulted in an imbalance in the airflow for CREVS; therefore, this event was not safety significant.
Example 2 - Red Mark Not Painted On Ductwork TVA considers that this example was the result of the prioritization of work activities.
Specifically, a work request was issued to paint the red mark on the ductwork after completion of flow balancing activities for CREVS.
Subsequently, operations personnel performed the valve lineup for this system as described in Operating Instruction, O-OI-31, Control Bay and Off-Gas Treatment Building Air Conditioning System, valve lineup checklist.
During the valve lineup activities, Operations personnel recognized that, there was not a red mark on the dampers and contacted the system engineer.
The system engineer verified that the dampers were locked in the correct position and that a work request had been generated to paint the red mark on the ductwork.
Based on this information, operations personnel signed off the valve lineup checklist.
Therefore, even though plant personnel did not meet the specific requirement in the procedure, the alignment was verified to be correct.
P
C ~
Example 3 - Valve Lineup Checklist TVA considers that this example was the result of an inappropriate personnel action.
The plant drawings associated with the installation of CREVS identified drain valve 0-DRV-31-7360 as part of a design change; however, this valve was not added to the valve lineup checklist (0-OI-31) as a result of a personnel oversight.
It is noteworthy that the drain line associated with this valve is capped; therefore, the position of this valve would not result in an imbalance of the airflow for the CREVS unit.
Thus, this event was not safety significant.
2 ~
Corrective Steps Taken And Results Achieved A.
Example 1 - Mispositioned Drain Valves B ~
TVA placed the identified valves in the closed position and removed the handles from the valves.
The handles have been located under the drain line to provide ready access, if needed.
These corrective steps will ensure that the valves will not be placed in the open position when opening the CREVS control panel.
Example 2 - Red Mark Not Painted On Ductwork C.
TVA implemented the work request to paint the red mark on the CREVS ductwork.
Additionally, TVA counseled the Operations personnel involved in this example on the importance of strict adherence to plant procedures.
Example 3 - Valve Lineup Checklist TVA added the drain valve to O-OI-31, Valve Lineup Checklist.
In addition, TVA reviewed modification activities associated with the Unit 2, Cycle 6, refueling outage to ensure that other valves had not been inadvertently left off the valve lineup checklists.
This review did not identify any other concerns.
3 ~
Corrective Steps That Have Been for will he] Taken To Avoid Further Violations No additional corrective steps are required to avoid further violations.
4 ~
Date When Full.Compliance Will Be Achieved TVA considers that full compliance has been achieved.
ENCLOSURE 2
Tennessee Valley Authority Browns Ferry Nuclear Plant.(BFN),
Reply to Notice of Deviation (DEV)
Inspection Report Number 50-259 260 296 93-23 RESTATEMENT OF DEVIATION "During an NRC inspection conducted on May 15 June 18,
- 1993, a deviation of a written commitment.was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the deviation is listed below:
The licensee stated in the Browns Ferry Nuclear Performance
- Plan, Volume 3 Section 2.2.2.3, Issuance of Configuration Control Drawings, that CCDs would be issued to replace as-constructed drawings and as-designed drawings to reflect the plant configuration and differences reconciled.
Contrary to the above, this commitment has not been met for the following two examples.
A Control Room Emergency Ventilation drawing for common equipment was not issued as CCD following modifications to the CREV system during the Unit. 2 Cycle six refueling outage.
The drawing (2-47E28654) was revised on April 21,
- 1993, and issued as an as-constructed drawing.
2.
Numerous Unit 1 and Unit 3 drawings have been issued as CCDs without a system walkdown and discrepancies resolved to reflect the actual plant configuration.
This deviation is applicable to all three units."
REPLY TO DEVIATION Reason Por Deviation Example 1 Drawing Hot Issued Rollowing Modification TVA considers that this example was the result of miscommunication during Phase I of the Design Baseline Verification Program (DBVP) at BFN.
Specifically, TVA committed in the Nuclear Performance Plan (NPP) to provide CCDs for equipment defined in the pre-restart phase (Phase I) of the DBVP prior to the restart of Unit 2.
To meet this commitment, TVA developed marked boundary drawings to identify the DBVP boundaries.
However, during the development of the shutdown board room boundary drawing, an additional drawing revision was issued which removed the Unit 2 shutdown board rooms from the boundary drawing and placed this information on a new drawing.
The individual performing the markup for the DBVP boundary was not aware of the drawing revision which resulted in the new drawing not being included in the CCD upgrade scope of the DBVP.
B ~
In the Inspection Report, NRC stated that the deviation occurred when "A Control Room Emergency Ventilation drawing for common equipment was not issued as CCD following modifications to the CREV system."
TVA does not consider that the NPP contains a commitment requiring CCDs to be issued for each modification.
Specifically, the NPP states that "...
CCDs will be established for other types of drawings if required to implement plant modifications.
Requirements for development of other CCDs will be included in design control procedures which are currently under development."
TVA considers that this statement describes a
program under development to address issuance of additional CCDs per requirements which were to be included in plant procedures.
TVA does not consider this to be a commitment to issue CCDs during implementation of every design change.
Example 2 - Issuance Of CCDs without A System Walkdown In this example, TVA implemented the lessons learned from the drawing upgrade process at BFN
during the restart of Unit 2 and did not consider this implementation to be a deviation from commitments made to NRC.
The lessons learned during the drawing upgrade process showed that once the deviations from prior documentation were reconciled on plant drawings then the as-constructed drawings were technically equivalent to CCDs even though plant walkdowns had not been completed.
Therefore, issuance of CCDs prior to the completion of plant walkdowns was not considered to be a deviation from NRC commitments.
It should be noted that the DBVP walkdowns were performed prior to issuance of Unit 3 drawings within the scope of the DBVP.
- However, an additional review of the specific commitments contained in both the BFN NPP and the June 13, 1991, submittal to NRC titled "Design Baseline Verification Program (DBVP)" indicates the procedural enhancements that were made to the CCD process were not in strict accordance with previous NRC commitments.
2.
Corrective Steps Taken And Results Achieved A.
Ezample 1 Drawing Hot Issued Following Modification B
TVA issued the affected drawing as a
CCD and has reviewed other drawings which were identified to be issued as CCDs during Phase I of the-DBVP.
This review did not identify any other concerns related to the issuance of CCDs during phase I of the DBVP.
Bzample 2 >> Issuance Of CCDs Withaut A System Walkdawn No immediate corrective steps were taken to address this example.
3 ~
Corrective Steps That Have Been [or will be] Taken To
.Avoid Further Vialations A
Bzample 1 Drawing Hot Issued Following Madification No additional corrective steps are required to address this example.
B.
Bzample 2 Issuance Of CCDs Without A System WalMom TVA will submit a description of the drawing upgrade process presently intended for use during the restart activities for Unit 1 and Unit 3 at BFN.
4.
Date When Full Compliance Will Be Achieved TVA will be in full compliance after submittal of the description of the drawing upgrade process presently intended for use during the restart activities for Unit 1 and Unit 3.
TVA intends to complete this submittal prior to September 30, 1993.
BNCLOSURB 3 Tennessee Valley Authority Browns Perry Euclear Plant (BFH)
List of Commitments TVA will submit a description of the drawing upgrade process presently intended for use during the restart activities for Unit 1 and Unit 3.
TVA intends to complete this submittal prior to September 30, 1993.