ML18038A886
| ML18038A886 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/29/1994 |
| From: | Machon R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9409130070 | |
| Download: ML18038A886 (14) | |
Text
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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CESSION NBR:9409130070 DOC.DATE: 94/08/29 NOTARIZED: NO FACIL: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 MACHON,R.D.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC violations noted in insp rept 50-259/94-17, 50-260/94-17
& 50-296/94-17.Corrective actions:temp controller has been calibrated to revised setpoint
& revise instrumentation setpoints,scaling
& calibration program.
DISTRIBUTION CODE: IEOID COPIES RECEIVED:LTR J ENCL i
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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
DOCKET 05000259 05000260 05000296 P
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1 RECIPIENT ID CODE/NAME WILLIAMS,J.
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N NOTE TO ALL"RIDS'ECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACTTHE DOCUMENTCONTROL DESK, ROOM Pl-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAMEFROM DISTRIBUTIONLISTS FOR DOCUMENTS YOU DON'T NEED!
AL NUMBER OF COPIES REQUIRED:
LTTR 21 ENCL 21
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Tennessee Valley Authority. Post Offce Box 2000, Decatur, Alabama 35609-2000 R. D. (Rick) Machon Vce President, Browns Feny Nuctear Rant August 29, 1994 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Gentleman:
In the Matter of Tennessee Valley Authority 10 CFR 2
Appendix C
Docket Nos.
50-259 50-260 50-296 BROGANS FERRY NUCLEAR PLANT (BFN) - NRC INSPECTION REPORT 50-259 260 296/94-17 REPLY TO NOTICE OF VIOLATION (NOV)
REGARDING ZNSTRUMENTATZON CALIBRATION AND SETPOINT DEFICIENCIES On July 28,
- 1994, NRC issued Inspection Report 94-17 that identified a violation regarding instrumentation calibration and setpoint deficiencies for a High Pressure Coolant Injection System flow indicating switch..
Enclosure 1 provides TVA's "Reply to the Notice of Violation" (10 CFR 2.201).
Enclosure 2 contains the commitments made in the reply.
If you have any questions regarding this reply, please telephone Pedro Salas, Manager of Site Licensing at (205) 729-2636.
Sincerely, R.
D.
chon Site Vice President Enclosure cc:
See page 3
9409130070 940829 PDR ADOCK 0500025'st 9
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.U.S. Nuclear Regulatory Commission Page 2
August 29, 1994 Enclosures cc (Enclosures):
Mr. Mark S. Lesser, Section 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. J.
F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852
~J
Ue ENCLOSURE 1
TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
REPLY TO NOTICE OF VIOLATION (NOV)
INSPECTION REPORT NUMBER 50-259'60'96/94-17 RESTATEMENT OF VIOLATION "During the Nuclear Regulatory Commission (NRC) inspection conducted on June 18 July 16,
- 1994, 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:
Technical Specification 6.8.1.1.a requires that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Paragraph 1.f of Appendix A requires procedures for the scheduling of surveillance tests and calibrations.
Site Standard Practice 6.8, Instrumentation Setpoint,
- Scaling, and Calibration Program for the calibration of plant instrumentation.
This program requires instruments to be calibrated at a specified interval using controlled calibration data.
Contrary to the above, on May 10, 1994, it was determined that the High Pressure Coolant Injection Minimum Flow Valve Flow Indicating Switch 2-FIS-073-0033 had not been calibrated for 37 months when its required calibration periodicity was 18 months.
Furthermore, it was determined that the flow indicating switch, when last calibrated, was set to less. conservative. parameters. than. those. specified. in.
the Nuclear Engineering Setpoint and Scaling Document issued in April, 1991.
Following identification of the above matter the licensee identified additional examples of failure to implement setpoint changes into the plant.
This is a Severity Level IV Violation (Supplement I)."
TVA's REPLY TO VIOLATION 1 ~
Reason For Violation The missed calibration occurred as a result of personnel error.
Personnel did not properly update the Preventive Maintenance (PM) program to reflect a change in the High Pressure Coolant Injection (HPCI) Minimum Flow Valve Flow Indicating Switch's unique identification number (UNID).
The UNID was revised to correct a discrepancy between the instrument label in the plant and the listing in the Equipment Management System (EMS) database.
A contributing factor was that the procedure for changing UNIDs Site Standard Practice (SSP)-6.3, "Preventive Maintenance Program" did not establish a mechanism for verifying that PMs were properly updated when UNIDs were revised.
The improper setpoints occurred as a result of not recalibrating the instrument following a change to the Nuclear Engineering Setpoint and Scaling Document (NESSD).
NESSD 2-F-073-0033-00-0, issued in April, 1991, changed flow switch 2-FIS-73-0033's setpoints from four (4) inches of water to nine (9) inches of water decreasing (low flow) and from 16 inches of water to 17.5 inches of water increasing (high flow).
When the NESSD was revised, the process for establishing setpoint changes did not contain a mechanism to ensure/verify implementation of the required changes.
Therefore, although the setpoint changes were approved, there was no verification of the implementation which resulted in the identified deficiency.
2 ~
Corrective Ste s Taken And Results Achieved The revised setpoints for the Unit 2 HPCI Minimum Flow Valve Flow Indicating Switch have been implemented and the instrument calibrated.
The instrument has been entered into the (PM) program using the correct UNID (2-FIS-73-0033).
This event has been reviewed with the appropriate Preventive Maintenance personnel.
TVA has revised SSP-6.8, "Instrumentation Setpoints, Scaling
.and Calibration Program," to require instrument setpoint changes to be issued via the Design Change (DCN) process.
- Thus, instrument setpoint changes are treated as field work with similar requirements for verification, testing, and closure.
TVA considers this an adequate interim action pending our further review of the NESSD change process described in Section 3 of this response.
TVA has reviewed those
- NESSDs, which affect Unit 2 operation, that were changed without a DCN.
Each of these NESSDs has been reviewed to determine if similar problems exist with calibration frequency, implementation of setpoint
- changes, or UNID discrepancies.
Of the NESSDs that were reviewed (approximately 367),
no similar problems were
identified where a missed calibration occurred as a result of a UNID change.
However, this review identified that setpoint changes for the following instruments had not been field implemented.
~
3-TIC-031-0660 Temperature indicating controller for the 3A2 Air Handling Unit, Heating, Ventilation and Air Conditioning (HVAC), Unit 3 Diesel Generator Building.
0-TC-031-0812 Temperature controller for the Control Bay Chiller 3A, HVAC.
0-TC-031-0827 Temperature controller for the Control Bay Chiller 3B, HVAC.
For 3-TIC-031-0660, the temperature controller has been calibrated to the revised setpoint.
While the temperature was set at a higher temperature than that specified in the NESSD, our assessment has determined that this difference would not cause any equipment degradation.
This determination is based on the redundant Diesel Generator Building Air Conditioning Units that were set correctly.
For 0-TC-031-0812 and 0-TC-031-0827 significant margins exist in the calculation that supports the HVAC capacities associated with the Control Bay Chillers 3A
& 3B.
Therefore, these conditions do not represent a safety concern.
TVA will take appropriate actions to resolve these discrepancies (i.e., revise the NESSD or recalibrate the instrument) by October 31, 1994.
Additionally, TVA's review of NESSDs changed without a DCN determined that 16 Emergency Diesel Generator (EDG) day fuel storage tank level switches (i.e.,
2 for each of the 8 EDGs) listed in the NESSDs are not in the PM program.
These switches control the transfer of diesel fuel oil from the 7-day storage tanks to the day tanks.
These instruments are required to 'be calibrated every 18 months; but: have not been calibrated. since. 1988.
This does not represent a safety concern since surveillances of the EDGs (e.g., routine verification of fuel oil tank levels, monthly diesel generator tests) verify the ability of these switches to perform their function.
These instruments have been added to the PM program.
Currently, 4 of the 16 switches have been calibrated during scheduled EDG outages.
The remaining switches will be calibrated as part of their respective EDG outage.
These outages are currently scheduled to be completed by March 15, 1995.
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3.
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Corrective Ste s That Have Been or Will Be Taken To Prevent Recurrence TVA is further evaluating the NESSD revision process.
Specifically, BFN's Independent Review and Analysis Group is evaluating the methodology for revising instrument setpoint changes to determine if additional corrective actions; or enhancements, are warranted.
This review will include an assessment of other utilities'rograms for revising instrument setpoints.
This review will be completed by October 15, 1994.
TVA will revise SSP-6.3, "Preventive Maintenance Program,"
to establish a mechanism for verifying that PMs are properly updated when UNIDs are revised.
This action will be completed by September 30, 1994.
TVA will review the remaining Unit 2 and common NESSDs to ensure that the components listed in these documents are in the PM program and are being calibrated to the correct frequency.
Discrepancies identified during this review will be dispositioned and any necessary actions scheduled prior to startup from the Unit 2 Cycle 7 refueling outage.
The Units 1 and 3 recovery efforts include activities for ensuring that instruments are calibrated at the proper setpoint and frequency (e.g.,
DCN closure process, System Plant Acceptance Evaluation/System Pre-Operability Checklist).
Therefore, any instrument deficiencies will be corrected as part of each unit's restart efforts.
Date When Full Com liance Will be Achieved Full compliance will be achieved by March 15,
- 1995, upon completion of the surveillance for the Emergency Diesel Generator day fuel storage tank level switches.
El-4
ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
REPLY TO NOTICE OF VIOLATION (NOV)
INSPECTION REPORT NUMBER 50-259'60~296/94-17 COMMITMENTS 1 ~
2.
4 ~
5.
TVA will take appropriate actions to resolve the discrepancies for instruments, 0-TC-031-0812 and 0-TC-031-0827 (i.e., revise the NESSD or recalibrate the instrument) by October 31, 1994.
TVA's review of NESSDs changed without a DCN also determined that 16 diesel day tank level switches listed in the NESSDs are not in the PM program.
These instruments have been added to the PM program and are being calibrated during their scheduled respective EDG outage.
These outages are currently scheduled to be completed by March 15, 1995.
TVA will revise SSP-6.3, "Preventive Maintenance Program,"
to establish a mechanism for verifying that PMs are properly updated when UNIDs are revised.
This action will be completed by September 30, 1994.
TVA will review the remaining Unit 2 and common NESSDs to ensure that the components listed in these documents are in the PM program and are being calibrated to the correct frequency.
Discrepancies identified during this review will be dispositioned and any necessary actions scheduled prior to startup from the Unit 2 Cycle 7 refueling outage.
BFN's Independent Review and Analysis Group is evaluating the. methodology for. revising instrument. setpoint. changes to.
determine if additional corrective actions, or enhancements, are warranted.
This review will include an assessment of other utilities'rograms for revising instrument setpoints.
This review will be completed by October 15, 1994.