ML20077B050

Responds to NRC Re Violations & Deviation Noted in IE Insp Repts 50-259/83-15,50-260/83-15 & 50-296/83-15. Corrective Actions:Schedule Sys & Plant Procedures Will Be Revised & Mechanical Maint Instructions Will Be Reviewed

ML20077B050
Person / Time
Site:	Browns Ferry
Issue date:	07/01/1983
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20077B038	List: ML20077B050
References
NUDOCS 8307220533
Download: ML20077B050 (6)

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.e TENNESSEE VALLEY AUTHORlWNRO REl!% :.

f CHATTANOOGA. TENNESSEE 37401

.400 Chestnut Street Tower II

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! 83JUL 7 A10 : 38 July 1, 1983 '

U.S. Nuclear Regulatory Commission Region II ATTN: -James P.'0'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303 4

Dear Mr. O'Reilly:

l Enclosed is our response to R. C. Lewis' May 26, 1983 letter to

H. G. Parris transmitting Inspection Report Nos. 50-259/83-15,

, -260/83-15, -296/83-15 regarding activities at our Browns Ferry

. Nuclear Plant which appeared to have been in violation of NRC ,

regulations. We have enclosed our responses to Appendix A, Notice of Violation and Appendix B, Notice of Deviation. We discussed the extension to July 1, 1983 in a telephone conversation between Bill

, Bradford of your staff and Mike Hellums of my staff on June 24,

!~ 1983 If.you have any questions, please call Jim Domer at FTS 4 858-2725.

. To the best of my knowledge,-I declare the statements contained 1 'herein are complete and true.

< ~Very truly yours, TENNESSEE VALLEY AUTHORITY i

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L. M. Mills, Manager

j. Nuclear Licensing  ;

Enclosure ll i

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j, 83072YO533 830715 DR ADOCK 05000 An Equal Opportun.4y Employer

i $tESPONSE - NRC INSPECTION REPORT NOS.

1 50-250.'83-15, 50-260/83-15, AND 50-296/83-15 i l R. C. LEWIS' LETTER TO H. G. PARRIS i DATED MAY 26, 1983 Actions to Improve Management Control Systems - Mechanical-Maintenance

a. Corrective actions to be taken to assure commitments are tracked and compliance assured.

Presently our plant' complianoe, staff provides tracking mechanisms for ensuring that commitments to NRC and others are tracked until plant procedures are changed or other corrective actions are completed.

Success of this effort is evident by our improvement over the past 2-3 t years in drastically reducing the number of deviations. However, just revising procedures does not always ensure complete compliance.

Scheduling systems should designate which procedures. involve commitments so that other considerations, such as manpower or schedule, do not override written coanitments. Also, procedures should have a method for distinctively identifying which item (s) are NRC commitments, to preclude the possibility o; unconsciously removing commitment items from procedures at a future date.

To this end, Browns Ferry will, to the extent practical, provide the i' indicators discussed above for previous commitment items in both the schedule system and in plant procedures. This will be based on available records from our computerized tracking system. On a long term basis, the division has and will continue to develop and implement l a program matrices system (reference IE Inspection 82-10) to provide l an overall, systematic approach to controlling commitments made and implemented in division procedures and instructions.

We will begin this effort in the mechanical maintenance area, and

4. extend to other areas in the near future. In addition, as soon as ,

plant procedures ca 2 be revised unique identifiers for new NRC  !

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commitments will be introduced into both our sch Ardule system and in the procedures themselves.

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R ' Also,. mechanical maintenance personnel have recently completed a "~

detailed review and revision of the scheduled maintenance system to 9ngure that all items are allotted adequate time for completion and are 'i

, properly sequenced. '

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j b. Corrective actions to be taken to correct potential loss in l reliability of RHRSW system due to repetitive failures of RHRSW air

vacuum valves. ,,

We believe the specific items regarding the RHRSW system have been adequately addressed in our response to both this report and in our revised response to report No. 81-28.

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c. Corrective actions to assure communication / procedures are clarified between maintenance and operational areas.

All mechanical maintenance instructions will be reviewed to ensure l preper coinnunications are established to prevent bypassing inspections, etc.

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d. Management attention to be taken that will assure compliance and increased plant safety reliability.

A Based on perceived NRC concern's regarding responsiveness and attention to possible safety problems, we very recently have added to the activities covered in our Daily Coordination Meeting a list of open NRC concerns. This has been effective in minimizing open items, correcting potential problems, and increasing both compliance and reliability.

Also, we have recently relocated an experienced engineer from our mechanical maintenance section to our compliance staff. One of this engineer's primary functions is to assist mechanical maintenance personnel regarding regulatory compliance and to provide a more independent look at mechanical maintenance activities. However, this personnel move has created a greater shortage in our mechanical maintenance section. One of our most immediate needs is filling the existing engineering vacancies in this section and will be given increased management attention. In addition, we are upgrading the

qualifications of both management and engineering personnel in this section through shift technical advisor (STA) and senior reactor operator (SRO) certification training.

4 Appendix A

!" Item 4 - (259, 260, 296/83-15-02) '

Technical Specification 6.3.A requires that detailed written procedures shall be prepared, approved, and adhered to as related to surveillance and maintenance procedures.

Contrary to the above, this was not met in that review of Surveillance " '

Instruction 4.5.C.2, RHRSW Functional Test, of March 23,'1983, indicated that,the required step 1.1, performance of Mechanical Maintenance Instruction 29, Inspection of RHRSti Pump Operation, was not conducted.

This is a Severity Level V violation (Supplement I). (This is applicable to Unit 3.)

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1. Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

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l Reasons for the Violation if Admitted 1

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The mason was procedural inadequacy. SI-4.5.C.2 and SI-4.5.C.3 previously did not require a sign-off by mechanical maintenance saying that applicable portions of MI-29 have been performed or did not require a listing of the person's name notified. All that was required  ;

was that the operator notify mechanical maintenance that SI-4.5.C.2 and SI-4.5.C.3 were being performed.

. 3 Corrective Steps Which Have n Taken and the Results Achieved The instructions and data sheets of SI-4.5.C.2 and SI-4.5.C.3 have been revised to ensure proper notification of the responsible maintenance supervisor on duty, to ensure the listing of the person's name that was notified, and to provide a sign-off on respective data sheets stating that mechancial maintenance has perforsned applicable. portions of MI-29.

4. Corrective Steps Which Will Be Taken To Avoid Further Violations The completed MI and SI data will be examined to verify compliance with the revisions made.

5. Date When Full Compliance Will Be Achieved Full compliance was achieved when .SI-4.5.C.2 and SI-4.5.C.3 were revised on May 2, 1983 Item B - (259, 260, 296/83-15-03) 10 CFR 50, Appendix B, Criterion V states in part that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances.

- % . Contrary to the above, this was not-met in that review of Electrical Maintenance Inst *uction (EMI) 57, HPCI Level Switch Calibration, indicated the procedure, as written,. was inadequate. Figure 1 of EMI 57 which i

denotes system test' configuration, is unusable since the water fill line~is~~

shown configured to fill the level switch chamber from the top vice the bott9gof the chamber. In actual calibrations, the system is filled from the bottom fill connections.

This is a Severity Level V violation (Supplement I). (This is applicable to all units.)

j 1. Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

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2. Reasons for the Violation if Admitted The HPCI inlet steam line drain pot can be filled from either the top or the bottom' isolation valve. However, the most practical and reliable means of setting steam line drain pot level switch LS-73-5 is by filling the drain pot free the bottom isolation valve. Personnel failed to follow plant-approved instructions denoting that the drain

, pot be filled from ,the top isolation ' valve.

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3. Corrective Steps Which Have Be'en Taken and the Results Achieved Electrical Maintenance Instruction 57 was revised June 2, 1983 to provide instructions for calibrating LS-73-5 by filling the drain pot from the bottom isolation valve.

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4. Corrective Steps Which Will Be Taken To Avoid Further Violations 4

Similar procedures for , condensate drain pot level switches LS-71-5 and i LS-73-8 (EMI 56 and 57, respectively) will be revised to provide instructions fcr calibrating the level switches by filling the drain i pot float chamber from the bottom isolation valve. Documented dis-cussion will be made with all electrical maintenance craft to point out that no deviations from instructions- can be made without proper.

! approved instruction revisions.

5. Date When Full Compliance Will Be Achieved Documented discussions will be made by July 15, 1983 Procedures will be revised by August 15, 1983.

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Appendix 5(259,260,296/83-15-01) j ;; . g -

Tennessee Valley Authority's letter dated November 27, 1981, in response to R. C. Lewis' letter dated October 20, 1981 which transmitted Inspection Report 50-259/260/296/81-28, stated that, in regard to Appendix A, Violation B, an inspection.of residual heat removal service water air vacuum valves would be conducted every operating cycle. -  ;~ ~

i Contpary to the above, a review of records and discussion with plant staff indicated no inspection was conducted during 'the unit 2 operating cycle '

completed on March 20, 1983

1. Corrective Steps Which Have Been Taken -

1 On April 18, 1983, a.irisual inspection of all 12 RHRSW valves was made to determine the type of valves and manufacturer, and to see if any visual damage was present. No visual ammare was found. Five of the twelve valves were identified as being of the old style APCO valve. A meeting was held with members of the plant and the NRC resident inspector in which the findings of the previous day were discussed.

The general agreement between the members of the meeting was to either buy five new valves _of the improved type and change out all five old J

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style problem APCO valves or disassemble the valves and inspect the internals if purchase and changeout could not be accomplished within 30 days. Five new valves were purchased and installed and a follow-up to Report 81-28 was sent to NRC June 10, 1983 describing these e.ctions.

2. Corrective Steps Which Will Be Taken To Avoid Further Deviations Based on the description provided in revised response to Report 81-28, changing valve types in and o'f itself should preclude any further problems. Inspection in accobdance with IMI-29 will be performed.

3 Date Corrective Actions Will Be Completed Full compliance was achieved in May 1983 when the last old .tyle valve was changed out.

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