ML18038A921

LER 93-010-00:on 940822,discovered That on 930525,primary Containment for Facility Restored W/O LLRT Having Been Performed Due to Inadequate Procedures & Drawings.Applicable Drawings & Procedures Will Be revised.W/940920 Ltr

ML18038A921
Person / Time
Site:	Browns Ferry
Issue date:	09/20/1994
From:	Machon R, Jay Wallace TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-93-010-01, LER-93-10-1, NUDOCS 9409290279
Download: ML18038A921 (20)

Text

j. ~A~~L l. I (ACCELERATED RIDS PROCESSING)

I.

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9409290279 DOC.DATE: 94/09/20 NOTARIZED: NO, DOCKET FACIL:50-260 Browns Ferry Nuclear Power -Station, Unit 2, Tennessee 05000260 AUTH. NAME AUTHOR AFFILIATION WALLACE,J.E. Tennessee Valley Authority MACHON,R.D. Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 93-010-00:on 940822,discovered that on 930525,primary containment for facility restored w/o LLRT having been performed due to inadequate procedures. & drawings. Applicable drawings & procedures will be revised.W/940920 ltr.

DISTRIBUTION CODE: IE22T 'COPIES RECEIVED:LTR.

TITLE: 50.73/50.9 Licensee Event Report (LER),

6Incident ENCL t SIZE:

Rpt, etc.

'NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-4-PD 1 1 WILLIAMS,J. 1 1 INTERNAL: ACRS 1 1 EOD/~OAB/DSR AEOD/SPD/RRAB 1 1 FI LE CENTER 02>

NRR/DE/EELB 1 1 /DE/EMEB NRR/DORS/OEAB 1 1 NRR/DRCH/HHFB NRR/DRCH/HICB 1 1 NRR/DRCH/HOLB NRR/DRSS/PRPB ,2 2 NRR/DSSA/SPLB NRR/DSSA/SRXB 1 1 NRR/PMAS/IRCB-E RES/DSIR/EIB 1 1 RGN2 FILE 01 EXTERNAL: EG&G BRYCE,J.H 2 2 L ST LOBBY WARD 1 NOAC MURPHY,G.A 1 1 NOAC POORE,W. 1 NRC PDR 1 1 NUDOCS FULL TXT 1 iiOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE iVASTE! COYTACTTHE DOCL'ME4T CONTROL DESK, ROOM Pl-37 (EXT. 504-2083 ) TO ELIiIIiATE'YO!:RiAME FROil DISTRIBUTION. LISTS I'OR DOC L'iIEN'I'S YOL'Oi "I'LED!

..FULL TEXT CONVERSION REQUIRED, TOTAL NUMBER OF COPIES REQUIRED: LTTR 27 ENCL 27

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Tennessee Yeses'ot,'ersy, Post 0'.rise Sox 2000. De~a:o;A'a~>ra 35609 2000 R. D. (Rick) Machos Vee Presdent, Srowrs F'e.ry Nootea~ Ptant September 20, 1994 U.S'. Nuclear Regulatory Commission 10 CFR 50.73 ATTN: Document Control Desk Washington, D.C. 20555

Dear Sir:

BROWNS FERRY NUCLEAR PLANT (BFN) UNZTS ig 2g AND 3 DOCKET NOS ~ 50 259@ 50 260@ AND 296 FACZLZTY 'OPERATZNG LZCENSE DPR 33~ 52~ AND 68 LICENSEE EVENT REPORT 50-260/93010 The enclosed report provides details concerning a Technical Specifications requi.red local leak rate test (LLRT) that was not performed following a planned work activity on February 25, 1993, during the Unit 2 Cycle 6 refueling outage. Primary containment for Unit 2 was restored on May 25, 1993. Thus, this event became reportable on thi's date as a condition prohibited by the plant TS existed. TVA discovered this event on August 22, 1994 as part of a programmatic review of commercial grade items. The event resulted from inadequate documentation regarding primary containment boundaries, in that procedures and drawings did not clearly distinguish those components that are part of the primary containment boundary.

This report is submitted in accordance with 10 CFR 50.73 (a) (2)(i)(B) .

A list of commitments is provided in Section VII of the enclosed report.

Si r ly, R. D. Machon Site Vice President Enclosure cc: See page 2 lpP 9409290279 940920 PDR ADQCK 05000260 S PDR

U.S. Nuclear Regulatory Commission Page 2 September 20, 1994 cc (Enclosure):

INPO Records Center Suite 1500 1100 Circle 75 Parkway Atlanta, Georgia 30339 Paul Krippner American Nuclear Insurers Town Center, Suite 300S 29 South Main Street West Hartford, Connecticut .06107 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611 Regional Administrator U.S. Nuclear Regulatory Commission Region 101 II Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. J. F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852

0 NRC FORH 366 .S. NUCLEAR REGULATORY CQIIISSION ROVED BY QNI NO. 3150-0104 (5-92) EXPIRES 5/31/95 ESTIHATED BURDEN PER RESPONSE TO COMPLY IIITH THIS INFORHATION COLLECTION REQUEST: 50.0 HRS LICENSEE EVENT REPORT (LER) FORNARD COMMENTS REGARDING BURDEN ESTIHATE TO THE INFORMATION AND RECORDS HANAGEHENT BRANCH (HNBB 7714), U.S. NUCLEAR REGULATORY COMHISSIOH, (See reverse for required number of digits/characters for each block) WASHINGTON, DC 20555-0001, AND TO THE PAPERNORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEHENT AND BUDGET NASHINGTON DC 20503.

ACILITY NAME (1) DOCKET NQIBER (2) PAGE (3)

.Browns Ferr Nuclear Plant BFN Unit 2 05000260 1 OF 7 ITLE (4) A Technical Specifications required surveillance test was not performed due to inadequate procedures and drawings.

EVENT DATE 5 LER HISIBER 6 REPORT DATE 7 OTHER FACILITIES INVOLVED 0 SEQUENTIAL REVISION FACILITY NAHE NA DOCKET NUHBER MONTH DAY YEAR YEAR HOHTH DAY YEAR HUHBER NUHBER FACILITY NAHE NA DOCKET NUHBER 05 25 93 93 010 00 09 20 OPERATING TH IS REPORT IS SUBIIITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR  : Check one or more 11 H(X>E (9) N 20.402(b) 20.405(c) 50 '3(a)(2)(iv) 73.71(b)

PONER 20.405(a)(1)(i) 50.36(c)(1) 50.73(a)(2)(v) 73.71(c>

96 '6(c)(2)

LEVEL (10) 20.405(a)(1)(ii) 50 50.73(a><2><vii) OTHER 20.405(a)(1)(iii) 50.73(a)(2)(i)(B) 50.73(a)(2)(viii)(A) (Specify in 20.405(a)(1)(iv) 50.73(a)(2)(ii) 50.73<a)(2)(viii)(B) Abstract and in Text, below 20.405(a)(1)(v) 50.73(a)(2)(iii) 50.73(a)(2)(x) NRC Form 366A LICENSEE CONTACT FOR THIS LER 12 NAHE TELEPHOHE NUMBER (Include Area Code)

James E. Wallace, Compliance Licensing Engineer (205)729-7874 CQIPLETE ONE LINE FOR EACH CQIPONENT FAILURE DESCRIBED IN THIS REPORT 13 REPORTABLE REPORTABLE CAUSE SYSTEH COHPONENT MANUFACTURER CAUSE SYSTEH COMPONENT MANUFACTURER TO NPRDS TO NPRDS SUPPLEMENTAL REPORT EXPECTED 14 EXPECTED HONTH DAY YEAR YES SUBHISSION X NO (If yes, complete EXPECTED SUBHISSION DATE). DATE (15)

ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16)

On August 22, 1994, TVA discovered that a test connection valve, which was part of a primary containment boundary, was not tested pursuant to Technical Specifications (TS) 4.7.A.2.g. Specifically, a TS local leak rate test (LLRT) was not performed following maintenance on the valve internals on February 25, 1993, during the Unit 2 Cycle 6 refueling outage. Once the valve's internal parts were replaced, the valve should have had an LLRT prior to establishing primary containment. On May 25, 1993, (the event date of the LER) primary containment for Unit 2 was restored without the LLRT having been performed. Therefore; this event is reportable in accordance with 10 CFR 50.73 (a)(2)(i)(B) as a condition prohibited by the plant TS. The cause of this event was inadequate documentation regarding primary containment boundaries. specifically, plant drawings and procedures did not clearly distinguish those components that are part of the primary containment boundary. Applicable drawings and procedures will be revised accordingly. Additionally, Work Order 'Planners and Work Order personnel have been trained on the criteria for a 'primary containment boundary.

NRC FORM 366 (5-92)

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NRC FORM 366A U.S. NUCLEAR REGULATORY C(HHIISSION APPROVED BY (Hts NO. 3150-0104 (5-92) EXPIRES 5/31/95 ESTIHATED BURDEN PER RESPONSE TO COMPLY'WITH THIS IHFORHATION COLLECTION REQUEST: 50.0 HRS. FORWARD COHHEHTS REGARDING BURDEN EST IHATE TO THE INFORMATI OH AND RECORDS HANAGEMENT LICENSEE EVENT REPORT BRANCH (HHBB 7714), U.S. NUCLEAR REGULATORY COMHI SSION, TEXT CONTINUATION IIASHINGTOH, DC 20555-0001, AND TO THE PAPERWORK REDUCT ION PROJECT (3150-0104), OFFICE OF HANAGEHENT AND BUDGET, WASHINGTON, DC 20503 FACILITY NAHE (1) DOCKET NQ(BER (2) LER NWBER (6) PAGE (3)

'EAR SEQUEHT IAL REVISION NUHBER NUHBER Browns Ferry Unit 2 05000260 93 010 00 2 of 7 TEXT If more s ce is r ired use edditionst co ies of NRC Form 366A (17)

PLANT CONDITIONS At the time of event discovery, Unit 2 was at approximately 96 percent power (3164 megawatts thermal) and Units 1 and 3 were shutdown and defueled.

IZ DESCRIPTION OF EVENT A. Event On August 22, 1994, TVA discovered that a reportable event existed because test connection valve (TV)(2-TV-64-562)[V) had not been leak rate tested, pursuant to Technical Specifications (TS) 4.7.A.2.g. The TV was within the primary containment boundary between two flow control valves (2-FCV-64-31 and 2-FCV 140)[ISV) for drywell penetration 2-X-26 (See Znsert).

FCV FCV

'2+CV+1.3 I 2+'CV44-1 40 2-TV&562 Pcnctsction 2-X-26 2-TV%%$ 3 To Pcnctratlon 2-)(-231 The event was discovered during a programmatic review of commercial grade items (CGIs). Work order 93-023462-00 was evaluated because of the replacement of internal parts (bonnet, stem, disc and packing) of the TV. These internal parts were

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NRC FORM 366A. U.S. NUCLEAR REGULATORY CQIIISSION APPROVED SY (WB NO. 3150-0104 (5-92) EXPIRES,5/31/95 ESTIMATED BURDEN PER RESPOHSE TO COMPLY lllTH THIS INFORMATION COLLECT ION REQUEST: 50. 0 HRS ~ FORl!ARD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT LICENSEE EVENT REPORT BRANCH (MHBB 7714), U.ST NUCLEAR REGULATORY COMMISSION, TEXT CONTINUATION 'MASHINGTOH, DC 20555-0001, AND TO THE PAPERHORK REDUCTIOH PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDGETS NASMINGTON, DC 20503 FACILITY NAME (1) DOCKET NUMBER (2) LER NINER (6) PAGE (3)

TEAR SEQUEHI' AL REVISION NUMBER NUMBER Browns Ferry Unit 2 05000260 93 010 '00 3 of 7 TEXT If more s ce is r uired use additional co ies of HRC Form 3 66 A (17) replaced on February 25, 1993, during the Unit 2 Cycle 6 refueling outage as part of a planned work activity. The work order planner did not recognize that this valve was part of a primary containment 'boundary. Thus, a local leak rate test (LLRT) was not specified in the work order.

On May 25, 1993, primary containment for Unit 2 was restored.

Thus, this event became reportable on this date as a condition prohibited by the plant TS existed. This condition existed until July 12, 1993, at which time, a TS 4.7.A.2.g LLRT was performed on the TV during, another work order (93-09218-00) following repairs made to flow control valve 2-FCV-64-140 [ISV]'. During this test, leaks did not exceeded TS allowable limits This event is reportable in accordance with 10 CFR 50.73 (a)(2)(i)(B) due to a condition prohibited by the plant Technical Specifications that existed from May 25, 1993 until July 12, 1993.

B. Ino erable Structures Com onents or S stems that .Contributed to the Event:

None.

C. Dates and A roxima'te Times of Ma'or Occurrences February 25, 1993 TV 2-TV-64-562 maintenance instruction was performed, and valve was leak tested to 1.5 psig.

May 25,. 1993 Primary containment for Unit 2 was restored.

July 12, 1993 TV received a TS LLRT after the repair of 2-FCV-64-140.

August 22, 1994 System Engineer discovered that an LLRT was not performed after the repair of 2-TV-64-562 on February 25, 1993.

D. Other S stems or Seconda Functions Affected:

None.

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NRC FCRN 366A U.S. NUCLEAR REGULATORY CQHIISSION APPROVED BY QI8 NO. 3150-0104

,(5-92) EXPIRES 5/31/95 ESTINATED BURDEN PER RESPOHSE TO CONPLY MITH THIS INFORHATION COLLECTION REOUEST: 50.0 BR'ORIJARD CONHEHTS REGARDING BURDEN ESTINATE TO THE IHFORNATION AND RECORDS NAHAGENEHT LICENSEE EVENT REPORT BRANCH (HHBB 7714), U.S. NUCLEAR REGULATORY CONHISSIOH, TEXT .CONTINUATION lJASHIHGTOH, DC 20555-0001, AHD TO THE PAPERHORK REDUCTIOI(

PROJECT (3150.0104), OFFICE OF HAHAGEHENT AHD BUDGET, UASHIHGTOH DC 20503 FACILITY MANE (1) DOCKET NQQER (2) LER IRNBER (6) PAGE (3)

YEAR SEQUENTIAL REVI SI OH NUHBER HUNGER Browns Ferry Unit 2 05000260 93 010 00 4 of 7 TEXT !f more s ce is r ired use additional co ies of HRC Form 3 66A (17)

E. Method of Discove The event was discovered during an ongoing investigation of CGIs to determine past if maintenance.

the correct replacement parts were used during During the review, it was discovered that the wrong replacement parts were placed in the TV. When this was noted a problem event report (PER)(BFPER940576)'as initiated. As part of the PER evaluation process, an operability evaluation for the subject valve was performed. This evaluation included a review to determine if a .LLRT had been performed after the TV was repaired.

Upon reviewing a computer database for the performance of LLRTs, it was discovered by the System Engineer on August 22, 1994, that the required TS LLRT had not been performed for valve 2-TV-64-562.

F. 0 erator Actions:

None.

G. Safet S stem Res oases:

None.

CAUSE OF THE EVENT A. Immediate Causes The planner for work order 93-023462-00 was not aware that this TV was a part of a primary containment boundary. Consequently, on February 25, 1993, the TV was leak tested at 1.5 psig in accordance with a generic maintenance instruction for globe valves (MCI-0-000-GLV001) instead of the TS LLRT surveillance instruction (2-S1-4.7.A.2.g-3/64e),.

II ~ >

NRC FORM 366A U.S. NUCLEAR REGULATORY CQIIISSION APPROVED BY (NB NO. 3150-0104 (5-92) EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPOHSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT LICENSEE EVENT REPORT BRANCH (MHBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, TEXT CONTINUATION WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON DC 20503 FACILITY NAME (1) DOCKET Nil(BER (2) LER N(ABER (6) PAGE (3)

YEAR SEQUEN I I AL REVISION NUMBER NUMBER Browns Ferry Unit 2 05000260 93 010 00 5 of 7 TEXT If more s ce is r ired use additional co ies of NRC Form 3 66 A (17)

B. Root Causes The cause of the event was due to inadequate documentation regarding primary containment boundaries. Plant procedures (i.e.,

SSP-8.7 "Containment Leak Rate Programs" and SSP-6.50 "Post Maintenance Testing" ), that were used in the planning stage, did not clearly identify that the TV and similar valves required a TS LLRT. These procedures only listed ma)or isolation valves that establish primary containment boundaries and not test connection valves. Additionally, plant drawings did not clearly identify those components that are part of primary contai.nment boundaries.

IV ~ ANALYSIS OF THE EVENT An LLRT was performed on July 12, 1993, in accordance with the TS LLRT requirements for a work order that made repairs on a primary containment penetxation outboard isolation valve (2-FCV-64-140).

Testing 2-FCV-64-140 included pressurizing the TV. The successful completion of this TS LLRT on July 12, 1993, confirmed that the TV would have adequately fulfilled its intended safety function at a pressure of 49.6 psi as required by TS. The leakage measured during this test was within,allowable TS limits. Therefore, the affected TV would have functioned as expected. Consequently, plant safety was not adversely affected, and the safety of plant personnel and the public was not compromised.

V, CORRECTIVE ACTIONS A. Immediate Corrective Actions:

Work order Planners and work control personnel were trained to understand the criteria for a primary containment boundary and to contact the primary containment System Engineer for assistance if a component is located in a primary containment boundary. This action heightens their awaxeness of the need to evaluate whether a TS LLRT is requi.xed on outstanding work orders.

NRC FORH 366A U.S. NUCLEAR REGULATORY C(NIIISSION APPROVED 'BY (WB NO. 3150-0104 (5.92) 'XP I RES 5/31/95 ESTIHATED BURDEN PER RESPONSE TO COHPLY 'MITH THIS INFORHATION COLLECTION REQUEST: 50.0 BR'ORllARD COHHENTS REGARDING BURDEN ESTIHATE TO THE INFORHATION AND RECORDS HANAGEHENT LICENSEE EVENT REPORT BRANCH (HNBB 7714), U.ST NUCLEAR REGULATORY COHHISSION, TEXT CONTINUATION NASHINGTON, DC 20555-0001, AND TO THE PAPERNORK REDUCTION PROJECT (3'150-0104), OFFICE OF HANAGEHENT AND BUDGET, NASHINGTON DC 20503 FACILITY NAHE (1) DOCKET N(NBER (2) LER NNIBER (6) PAGE (3)

TEAR SEQUENTIAL REVISION NUHBER NUHBER Browns Ferry Unit 2 05000260 93 010 00 6 of 7 TEXT If more s ce is r ired use additional co ies of NRC Form 366A (17)

B. Corrective Actions to Prevent Recurrencet

1. The Containment Leak Rate Programs procedure will be revised to include test connection, drain and vent valves that are a part of a primary containment boundary. Appropriate maintenance procedures will be revised to reference the Containment Leak Rate Programs procedure. These revisions will ensure the, maintenancecontainment personnel are aware of the valves that are within a primary boundary.

2. Plant drawings will be revised to clearly distinguish primary containment boundaries consistent with testing requirements currently identified in the primary containment leak rate instructions.

3. As an interim action until actions 1 and 2 are completed, Work Order Planners and Work Control personnel will continue the immediate corrective actions described above.

VI ~ ADDITIONAL INFORMATION A. Failed Com onents:

None.

B. Previous LER on Similar Eventsi Previous Licensee Event Reports were reviewed for the following criteria: incomplete surveillance, double isolation design orders.

criteria, inadequate procedure, and inadequate work However, only LER 259/89003 addressed a problem relating to double isolation for primary containment. LER 259/89003 was generated after it was discovered that a single failure (loss of unqualified air supply) for the suppression pool vacuum relief butterfly valve would not provide a double isolation of primary containment. The LER 259/89003 event was due to a design problem.

The corrective action (air supply from a qualified pneumatic supply) to ensure the butterfly valve would operate properly would not have precluded the event in this LER (260/93010).

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NRC FORH 366A U.S. NUCLEAR REGULATORY CQNIISSION APPROVED BY QRI NO. 3150-0104 (5-92) EXPIRES 5/31/95 ESTIHATED BURDEN PER RESPONSE TO COHPLY WITH THIS IHFORHATION COLLECTION REQUEST: 50.0 HRS. FORNARD COHMENTS REGARDING BURDEN ESTIHATE TO THE IHFORHATIOH AND RECORDS HANAGEHENT LICENSEE EVENT REPORT 'RANCH (HNBB 7714), U.S. NUCLEAR REGULATORY COHHISSION, TEXT CONTZNUATZON MASHINGTOH, DC 20555-0001, AND TO THE PAPERMORK REDUCTION PROJECT (3150-0104), OFFICE OF HANAGEHENT AND BUDGETS IIASHINGTON DC 20503 FACILITY NAHE (1) DOCKET HWBER (2) LER NNBER (6) PAGE (3)

YEAR SEQUENTIAL REVI S ION NUHBER NUHBER Browns Ferry Unit 2 05000260 93 010 00 7 of 7 TEXT tf more s ce is r uired use sdditionst co ies of NRC'Form 366A (17)

VII ~ Commitments The Containment Leak Rate Programs procedure will be. revised to include test connection, drain and vent valves that are a part of a primary containment boundary. Also, appropriate maintenance procedures will be revised to reference the Containment Leak Rate Programs procedure. These revisions will ensure the maintenance personnel are aware of the valves that are within a primary containment boundary. These revisions will be complete by December 1, 1994.

2 ~ Plant drawings will be revised to clearly distinguish primary containment boundaries consistent with testing requirements currently identified in the primary containment leak rate instructions. These drawing revisions will be complete by Apri.l 15, 1995.

3. As an interim action until actions 1 and 2 are completed, Work Order Planners and Work Control personnel will continue the immediate corrective actions described above.

Energy Industry Zdentification System (EZZS) system and component codes are identified in the text with brackets (e.g., (XX].