ML20041C617
| ML20041C617 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/15/1982 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20041C572 | List: |
| References | |
| NUDOCS 8203020388 | |
| Download: ML20041C617 (5) | |
Text
n.
Y ;~
CAe h.
an ss 5 ytym e
_se' TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374o1
- i 'r^s
'C 400 Chestnut Street Tower II bd ' # " D
'c3' January 15, 1982 Mr. James P. O'Reilly, Regional Administrator U.S. Nuclear Regulatory Commission Region II - Suite 3100 101 Marietta Street
/
Atlanta, Georgia 30303
/0
Dear Mr. O'Reilly:
Please reference R.' C. Lewis' October 20, 1981 letter to H. G. Parris regarding Report Nos. 50-259/81-28, -260/81-28, and -296/81-28, L. M.
Mills' response to that report dated November 30, 1981, and R. C.
Lewis' letter to H. G. Parris dated December 14, 1981 regarding these same report numbers.
This is in response to R. C. Lewis' December 14, 1981 letter and to the concerns expressed in the telephone conversation between Floyd Cantrell and Jim Domer on December 11, 1981. We believe that in the conversation any concerns involving Item B of Appendix B of the report were resolved.
Enclosed is our supplementalsresponse to Item A of Appendix B.
\\
(d
/
Our original response stated that'RHRSW pumps A3, B3, C3, and D3 have always been tested with the original RHRSW pumps during the performance of MMI-19, the response being based on statements made by plant personnel familiar with the testing. However, following discussions between the resident inspector and the Compliance Staff Supervisor at Browns Ferry, a detailed investigation was made to determine whether the testing data (MMI data sheets and operator logs) supported this statement. This investigation did not fully support the original response as delineated in the enclosed supplemental report. TVA regrets that at the time of the original response a more detailed investigation was not conducted. We are making every effort to ensure that all statements in responses to inspections, etc., can be fully substantiated and documented.
I OFFICIg0Fi
&, O b
!@ S EEoEE N; An Equal Opportunity Employer,
i
.. -.. _ _ _ _~ ___ __ _. _ _ _. _ _, _
3, I
i 1
Mr. James P. O'Reilly January 15, 1982 l
i i
I i
+
i A two-day extension on this response was approved by F. S. Cantrell on January 11, 1982. An additional five-day extension was discussed with t
i C. Burger of your staff on January 14, 1982.
i j
If you have any questions regarding this matter, please call Jim Domer j
at FTS 858-2725.
1 To the best of my knowledge, I declare the statements contained herein i-are complete and true.
l Very truly yours, i
l TENNESSEE VALLEY AUTHORITY l
L.
. Mills, Manager Nuclear Regulation and Safety Enclosure l
I I
l i
p i
i a
i 4
l l
u t
E
' - w ~new
,ww
. w w ww,r -+<
vw-.-----
-,e-~~~
SUPPLEMENTAL RESPONSE - NRC INSPECTION REPORT NOS.
+*
50-259/81-28, 50-260/81-28, AND 50-296/81-28 R. C. LEWIS' LETTER TO H. G. PARRIS DATED OCTOBER 30, 1981 O
1 APPENDIX B Item A - (259/81-28-07, 260/81-28-04, 296/81-28-04)
The Browns Ferry FSAR, volume 7, Q2.6.5 requires that at specified intervals the residual heat removal service water (RHRSW) pump compartments will be flood tested to demonstrate each RHRSW pump operability during the test. Additionally, it is specified that the test will require filling each compartment to a depth of 18 inches of water.
Contrary to the above, a review of records and observation of Mechanical Maintenance Instruction 19 indicates that only eight of the twelve RHRSW pumps are routinely scheduled for the flood test. RHRSW pumps A3, B3, C3, and D3 are not scheduled for testing and the RHRSW compartments flood test is only conducted at the 6 inch water level.
1.
Corrective Steps Which Have Been or Will Be Taken TVA deviated from its FSAR commitment in that all pumps were not tested at specified intervals (each year as specified by MMI-19) and that the RHRSW compartment flood test is conducted at a six-inch level and not at the 18-inch level as specified in the FSAR. The FSAR volume 7, Q2.6-5 states "The test will be accomplished by filling each compartment to a depth of 18 inches, then demonstrating
)
the operation of each RHRSW pump." We believe that the intent of
/
this statement was to demonstrate that a RHRSW pump would run as if its compartment was flooded and that the six-inch test level is sufficient to demonstrate operability of the affected equipment. We have conducted a more extensive review of the FSAR, the instruction MMI-19, previous test records for MMI-19, and appropriate operator logs for those dates when MMI-19 was performed. The results of our review are summarized as follows.
1977 - Data sheets from MMI-19 indicate this test was performed on November 17, 1977, between approximately 0830 and 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br />. The data sheets also indicate that RHRSW pumps A1, A2, B1, B2, C1, C2, D1, and D2 were satisfactorily tested for operation with 6 inches of water in the compartment in accordance with the written instructions contained in MMI-19.
The assistant shift engineer's (ASE) logs for unit 2 and unit 3 for that date during the time of performance of MMI-19 indicate that C3 and D3 RHRSW pumps were running continuously during the test. (This is in keeping with Browns Ferry Nuclear Plant operating practice of running one RHRSW pump on each emergency equipment cooling water (EECW) header to keep the header charged. A3 and C3 pumps supply the north EECW header; B3 and D3 pumps supply the south EECW header.)
(v w
^
e-
4. -
We have interviewed the individual who performed MMI-19 on fr ~g that date and he does not recall operating either A3 or B3
)
during this test. Therefore, we can conclude that all pumps
\\d-other than A3 and B3 satisfactorily met the intent of the FSAR commitment in that operation during flooding conditions was demonstrated.
1978 - No test records are available. Therefore, it is concluded that no tests were performed. Nonperformance of the test is discussed in our response to violation C.2 in a letter from L. M. Mills to J. P. O'Reilly dated November 27, 1981.
1979 - Data sheets from MMI-19 indicate this test was performed on August 8, 1979, between approximately 0900 and 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br />.
The data sheets also indicate that RHRSW pumps A1, A2, B1, B2, C1, C2, D1, and D2 were satisfactorily tested for operation with 6 inches of water in the compartment in accordance with the written instructions contained in MMI-19.
The data sheets were also marked by the individual performing the test to indicate that A3, B3, C3, and D3 pumps were also satisfactorily tested to the 6-inch depth.
Therefore, we can conclude that all 12 RHRSW pumps satis-factorily met the intent of the FSAR commitment in that O-operation during flooding conditions was demonstrated.
N~-
1980 - No test records are available. Therefore, it is concluded that no tests were performed. Nonperformance of the test is discussed in our response to violation C.2.
1981 - MMI-19 data sheets indicate that RHRSW compartment A was tested on September 23, 1981, between approximately 0900 and 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br />; RHRSW compartment B was tested on September 16, 1981, between approximately 1200 and 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br />; RHRSW compartment C was tested on September 18, 1981, between approximately 0800 and 1030 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.91915e-4 months <br />; and RHRSW compartment D was tested on September 18, 1981, between approximately 0830 and 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />. The data sheets further indicate that A1, A2, B1, B2, C1, C2, D1, and D2 were satisfactorily tested at 6 inches of water in accordance with written instructions contained in MMI-19.
/
The unit 3 ASE logs for September 18, 1981, indicate that C3 RHRSW pump was running on that date. Therefore, we can conclude that the intent of the FSAR commitment was met for this pump in that operation during flooding conditions was demonstrated.
The unit 2 and unit 3 ASE logs for September 23, 1981, indicate that RHRSW pumps C3 and B3 were running at 0700
/' \\)
hours and that A3, L3 and D3 were running at 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br />.
(j This indicates that A3 and D3 pumps were started during the same shift when MMI-19 was performed in their compartment.
l I
.. ~
~
It is possible that these pumps were started or were running during IfMI-19, although an interview with the individual
,,/
performing the test was inconclusive.
j g
1 2.
Corrective Actions Which Will Be Taken to Avoid Further VioTa~tions Corrected MMI-19 data sheets will be used on future performance of the maintenance instruction.
As part of a general FSAR update, a FSAR review has been proposed to j
specify six inches instead of the present 18-inch fill requirement.
We believe that the test performed at the six-inch level is sufficient to demonstrate operability of the affected equipment; however, we are reevaluating the test method as prescribed by MMI-19 l
to ensure that the intentions of the original FSAR commitment are l
being met.
)
3 Date Corrective Actions Were or Will Be Completed IC3I-19 was revised and approved by PORC October 6,1981, to include A3, B3, C3, and D3 pumps on the data sheets. Reevaluation of the flood test method will be completed by January 22, 1982.
\\
i i
n 4
1
_,)
l; 1
1'.
l l
G,,,
-n,..~
,,_w
.,,. - -,. -