ML20064C912

Responds to NRC Re Violations Noted in IE Insp Repts 50-259/82-34,50-260/82-34 & 50-296/82-34.Corrective Actions:Ler of 820909 Event Re HPCI Condensate Header Low Level Switches Revised

ML20064C912
Person / Time
Site:	Browns Ferry
Issue date:	11/10/1982
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20064C867	List: ML20064C912
References
NUDOCS 8301040512
Download: ML20064C912 (6)

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TENNESSEE VALLEY AUTHORITY

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CH ATT ANOOGA, TENNESSEE 37401 400' Chestnut Street Tower II

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November 10, 1982 U.S. Nuclear Regulatory Commission Region II ATTN: James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Enclosed is our response to R. C. Lewis' October 7,1982 letter to H. G. Parris transmitting Inspection Report Nos. 50-259/82-34,

-260/82-34, -296/82-34 regarding activities at our Browns Ferry Nuclear Plant which appeared to have been in violation of NRC regulations. We have enclosed our response to Appendir A, Notice of Violation, and to Appendix B, Notice of Deviation. A two-day extension was discussed with F. Cantrell of your staff on November 9, 1982. If you have any questions, please call Jim Domer at FTS 858-2725.

To the best of my knowledge, I declare the statements contained herein are complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills, Manager Nuclear Licensing Enclosure 1

i 8301040512 821206 PDR ADOCK 05000259 G PDR '

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RESPO?!SE - NRC INSPECTION PEPORT FOS." $' /

50-259/82-34, 50-260/82-34, AMD,50-296/82-318 5 R. C. LEWIS' LETTER TO H. G. PARRIS ./,'" , '

DATED OCTOBER 7, 198) '

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Appendix A ' # ' 6

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Iten A - (25o/82-34-02) /

r h' <f Technical Specification 6.7.a requires that events fisted shall be re'orted i p as exoaditiously as possible, htit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> t0' the appropriate Regional office. #1 ,;

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. Contrary to the above, the requirenent was not net'in that on Septenher 9, 1982, !!PCI condensate hender low level suit,ches LS73-56A and B were found inoperative during the perfornance of Survei', lance Instruction 4J2.B.26 The report to Region II was given gn Sept' ember 14, i10P2, with a date o&

Septenber 13, 1982, listed as tho'dste 'of o' ecurren5n. ;

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,' This is a Feverity Level IV Violation (Funp:crpnt. I))' a;d is applicable to Unit 1.

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1. Adnission or Denial or the A11eend',1/iolation "

TVA admits the violation occurred as' stateri. - , i I

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s'l t Reasons for the Viointion if Admitted , f, - ',; y f The event was not deterrained reportable't ntil Septe'::Spr 13,;1982. ThiQi2 ,

date, rather than the event date, uas inadver[.entlN listed on the 1

y 'I'j licensee event report (LER) . The event'W afrerprted as required. Sh5 l 4

administrative error regarding the date of the event had no-bearing oB, ,,'

i the evaluation of the event and in our . view @as a minor safety .g f

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I si gnificance. We feel the violation shwld'be appropriately classified. l '

as a Level V violation. )

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3 Corrective Stens Fhich Have Been Taken an9_the Re':ults Achieved

• l i i The LER has been revised to reflect the events as,they r" curred.

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, s, 4 Corrective Stens "hich Pill De 'Paken To Avoid Fund,rl'iiointiens -

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A review of past reporting practices bas not reven:cd any problen 11th

the event evaluating and renortine progran.' ,e '

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5. Date Phan Full Conpliance '/ill neAchleidf, .e

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Mot applicable.

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Etan B - (250, 260, 206/82-34-09)

Tachnical Specificat' ion 5.3.A recuires detailed written procedures sball be i l' JTMhpared, approved, and adhered to for testing requirements. Mechanical l i ~!?aintenance~ Instruction (MMI) ?7 requires an up to date and accurate

. inventory of all Critical Structure Systen and Corponent (CSSC) tools be

. enintained by the tool roon attendant.

s Contrary to the above, the requirenent was not met .in that during an inspection to verify the control of measuring equioment used on critical systens, the follouing discrepancies were noted:

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1. MMI 27 requires annual calibration of the Standard l' ensuring Pods (1" to 211") - No record exists to indicate these rods are neriodically

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s. calibrated. No traceability records were available for the inspector

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to revieu, i.:

,'~ .' 2. The 2set of 3rown-Sharp Jo blocks was inconplete with several blocks

,- I, '. 'nissing. Fo documentation was available to indicate whether the

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J nissing blocPs were necessary for CSSC use.

f , 3 On Attachment B of PPI 27 (Required Inventory of CSSC Tools), two tools are listed as required, but no record was available to indicate to the

- 'E' inspector uhere these tools we-e located. The tool room attendant said Is ~ .I he did not remember ever seeing these tools. The tools include a

, 10,000 pound, Model X, Dillion force gage and a Universal Level

, Protractor (7"to 12").

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'4 The required inventory tool list in MMI 27 has nunerous errors on the

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quantity of tools available for CSSC usa. Fxanples include:

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a. Inventory shows 27 torque urenches onsite; actually h1 are onsite.

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i > b. Dial indicator quantity; greater nunber available than indicated on

, inventory list.

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c. GEN-A-TAK tachoneters, two on inventory list; actually three available. <

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.The above list is only an example since almost every quantity category l _,, <

.> une in error.

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-; 5. Some tools were available for naintenance use but not listed on the

! ,.- attachment D tool list. Exanples include:

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.' a. Feeler gares not listed but used for CSSC use.

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b. Torque screwdrivers not listed but used for CSSC use.

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O This is a Severity Level V Violation (Suoplement I.) and is apolicable to Units 1, 2, and 3 -

1. Ad:11ssion or Denial of the A11eced Violation TVA admits the violation occurred as stated.

! 2. Reasons for the Violation if Admitted "aintenance personnel were not familiar with th'e details of the controlling procedure, MMI 27. )

3. Corrective Stenn "hich Have "een Taken and the Pesults Achieved The toolroon attendant has been instructed in the requirements of the controlling procedure.

4 ror"eetive Stens Ifhich t'111 Pe Taken to Avoid Further Violations l FMI 27 is being revieued and will be revised to rerove unnecassary

requirements and tools not required for CSSC work.

5. Date Whan Full Connlianca util pn nehteven Full comoliance will be achieved by December 15, 1082 uhen the M"I revision will be conpleted.

1 Iten C - (250, 260, 206/92 7h-06) 10 CPR 50, Appendix n criterion XII, as implemented by TVA Topical Report TR 75-1, paramraph 17.2.12, requires that neasuree shall be established to assure that instruments used in activities affecting quality are properly controlled and calibrated at specified periods to naintain accuracy within necessary linits.

Contrary to the above, the requirenent was not ret in that tenperature instrumentation (therroneters) used to deternine conpliance uith clant ,

technical specificacion liniting conditions for operation was not calibrated or cortified to nationally recoenized standards.

i Fxanples of where this type of tennarature instrurentation is used include:

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1. Local tenperature instrunentation on the standby liould centrol systen punn suction required by Technical Specification 3.4.C.2.

2. Local temperature instrunentation used for prinary coolant conductivity j verification required by Technical Specification 3.6

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4-3 Local tenperature instrunentation used for prinary coolant pH neasurenents required by Technical Specifications 3.6.

This is a Severity Level V Violation (Sunplement I) and is applicable to Units 1, 2, and 3

1. Adrinston or Denini of the A11eeed Violation TVA admits the violation occurred as stated. ,

2. Peasons for the Violation if Adnitted Temperature neasuring devices (thermoneters) were purchased to be accurate enough for technical specification applications. Plant personnel failed to recognize the significance of requiring written vendor certification of accuracy.

3 Corrective Stans '3hich unve Peen Taken and the Fesults Achieved Certification is available and will be obtained fron the supplier.

4. Corrective Stecs Phich Fill Be Taken To Avoid Further Violations Only certified thernereters uill be used to monitor tanceratures required by technical specifications. A calibration orogram will be established.

5. Date Phen Full Conoliance "ill De Achieved Full compliance will be achieved by January 1, 1983 when thermoneters used to nonitor tenperatures requi"ed by technical specifications will be certified and a calibration prog"an established.

Apnendix 9 Deviation (82 1!!-01) ,

! Licensee Event Penort 259/R1-07 dated fiarch 10, 1081, which recorted an i inocerable fire danner due to paint buildup on a broken euse link, stated a procedure would be written for insnection and preventive naintenance on all fire dampers.

Contrary to the above, as of September 3, 1982, no Drocedure had been generated to perforn the inspection of fire dancers; hcuever, the licensee has closed out Licensee Event Fenort 259/91-07 as having been conoleted.

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Resoonse The corrective action in LER BFRO-50-259/81007 related that a procedure would be writtan for the inspection and preventative maintenance of fire door dampers. In addition, the separated fusible link which initiated the event uas to be replaced. The insnection and maintenance activities were

, to be included in a detailed procedure which,was in the orocess of being prepared for all CSSC, radiological, and vital area doors. This inspection and maintenance step was inadvertently omitted fron the procedure.

The tracking procedure for action conmitments included the replacement of the separated link but did not list the needed procedure change. The link was replaced and the open iten was closed.

Corrective Actions uhich Have Been Taken or Will Re Taken f*f!I 116 uns revised on Septerber 10, 1082 to include an inspection of fire doors with automatic closing louvers. These louvers were all inspected per the revised procedure on September 11, 1082. An instruction menorandum has been written to the compliance staff personnel responsible for tracking connitments to verify all completed itens by oersonally viewing docunentation or having a written statement from responsible supervisors that all work has been completed.

Corrective Actions 'Jhich Will Be Taken To Avoid Further Daviations

!!o further action is required.

Date Corractive Actions Uere or Mill Pe Connleted l Corrective actions uere completed en October 2A, 1992.

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