ML20078M391
| ML20078M391 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/26/1983 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20078M384 | List: |
| References | |
| NUDOCS 8310250170 | |
| Download: ML20078M391 (9) | |
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N TENNESSEE VALLEY AUTggQY CHATTANOOGA. TFNNESSEE,374o,1 ; 74 400 Chestnut Street Tower II B3 SEP 28 P l : ll x
s September 26, 1983 U.S. Nuclear Regulatory Commission Region II ATTN: James P. O'Reilly,-Regional Administrator 101 Marie'ta Street, NW, Suite 2900 t
Atlanta, Georgia '30303
Dear Mr. O'Reilly:
Enclosed,is our response to R. C. Lewis' August 24,'1983 letter to
_f H. G. Parris transmitting Inspection Report Nos. 50-259/83-27,
-260/83-27, -296/83-27 regarding activities at our Browns Ferry Nuclear Plant which appeared.po have been in violation of NRC regulations. We have enclosed pur response to Appendix A, Notice of Violation and' Appendix B, Notice of Deviation. 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,.
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50-259/83-27, 50-260/83-27, AND 50-295/83-27 R. C. LEWIS' LETTER TO H. G. PARRIS DATED AUGUST 24, 1983 Appendix A Item A - 296/83-27-03 10 CFR 50, Appendix B, Criterion IX, as implemented by TVA's QA Topical Report, TVA TR75-1, paragraph 17.2.9 and the Operational Quality Assurance Manual OQAM, Part II, Section 6.4, requires that measurea shall be estab-lished to assure that special processes are controlled and accomplished using qualified procedures in accordance with applicable codes, standards, criteria, and other special requirements.
Contrary to the above, this requirement was not met in that temporary alterations were affected to the Unit 3 residual heat removal system in the form of temporary test pressure gauges without the issuance of a temporary alteration contrcl form or unreviewed safety question determination. The gauges were installed during recent pressure suppression chamber head tank system operability checka. The portable gauges were installed at PT-74-65 and PT-74-51 without the issuance of a maintenance request as required by Browns Ferry Standard Practice 7.6 and left installed after test completion without temporary alteration controls as required by Standard Practice 8.2 and the plant QA program.
This is a Severity Level IV Violation (Supplement I) and is applicable to Unit 3 1.
Admission or Denial of the Alleged ?iolation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted 2
The event occurred during a TVA effort to make operational the PSC head tank system in response to the senior resident inspector's concern regarding this system. During troubleshooting of system operability, test gauges were installed several times with proper controls to verify PT-74-51 and -65 were operating properly. Because of an oversight, the last time the gauges were installed they were not removed.
3.
Corrective Steps Which Have Been Taken and the Results Achieved The test pressure gauges were removed. The consequences of this event and the need for following procedure have been discussed with the personnel and foreman involved. The importance of following plant
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' procedure has been stressed with all instrument maintenance (IM) foremen and personnel in IM foremen and safety meetings. The section supervisor and foremen have been instructed to become more closely involved in the details of specific IM work in progress.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations No further corrective action is required.
5.
Date When Full Compliance Will Be Achieved Full compliance was achieved on July 29, 1983, when the test pressure gauges were removed.
Item B - 260/83-27-08 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings.
Contrary to the above, this requirement was not met in that several control circuit fuses in backup control panel 25-32 were found incorrectly installed not in accordance with design drawing 791E513, Sheet 5, or the Browns Ferry electrical equipment fuse identification list. Specifically, two Bussman MIC fuses were found in tne circuit in an inverted condition such that fuse failure and circuit faults would not be alarmed in the control room. Fuses F5 (Recirculation loop sample valve 2-299 control) and F8 (Reactor head vent valves 2-17 and 2-18 control) were inverted.
Additionally, it was noted that fuse F1 (Scram discharge volume isolation valve control) was used in an incorrect application not in accordance with industry standard (Bussman technical manual). Fuse F1 was identified ac a Bussman MIN type fuse to be used in circuits which require visual indica-tion only. Instead, the circuit configuration requires the silverplated indicating pin for positive alarm signal activation which includes MIC and FNA type fuses, but not MIN type fuses.
This is a Severity Level IV Violation (Supplement I) and is applicable to Unit 2.
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 incorrect installations occurred sometime between 1976 and the present.- Personnel responsible for fuse installation apparently did not have adequate training. There was also inadequate information available to personnel responsible for fuse replacement.
3.
Corrective Steps Which Have Been Taken and the Results Achieved I
Since 1976, a fuse report and electrical equipment identification list have been developed. This list is now available to personnel installing fuses. The incorrectly installed fuses were repisced or
. installed correctly on June 30, 1983 A survey of control panels was made and approximately 75 fuses were found to be the wrong fuso or were incorrectly installed.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations Fuse training for the present plant assistant shift engineers, 2
electrical engir.eers, and electricians is expected to be completed by January 1, 1984. A fuse identificaticn program is also being estab-lished. The unit operators will receive training on fuse replacement in step 3 (part 4) of their electrical training before becoming assistant shift engineers.
5.
Date When Full Compliance Will Be Achieved The fuse identifying program will be completed by the end of the unit 1, cycle 6, refueling outage. Training is expected to be completed by January 1, 1984.
Item C - 259, 260, 296/83-27-11 10 CFR 50, Appendix B, Criterion IVII, requires that sufficient records shall be maintained to furnish evidence-of activities affecting quality.
Consistent with applicable regulatory requirements, the licensee shall establish requirements concerning record retention and assigned responsi-bility. The Plant QA Manual, Part III, Section 4.1, requires that accountability of records be maintained.
Contrary to the above, this requirement was not met in that workplan 5712-(Identification.and Classification of Fuses in Electrical Panels 25-17,
.25-31, 25-32. Units 1, 2, 3) was unavailable for review. The inspector could not determine the completion status of workplan 5712. Workplan 5712
-is associated with activities involving the wholesale changeout and
' classification of numerous safety systems control circuit fuses.
4-This is a Severity Level V Violation (Supplement I) and is applicable to all units.
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted The violation occurred because at the time workplan 5712 was initiated, TVA procedures regarding QA requirements were inadequate and did n-t require records retention for all workplan typer. Workplan 5712 was one of many initiated to perform what was considered to be a mainte-nance activity and did not change the as-constructed drawings. As such, retention for workplan 5712 as a record was not required by plant procedure.
3 Corrective Steps Which Have Been Taken and the Results Achieved TVA has long since recognized the weaknesses of its original records retention program and has previously taken strong, positive steps to correct and improve problem areas. Records retention requirements for workplans and modifications are spelled out in detail in plant Standard Practice 8.3 and in the Operational Quality Assurance Manual (Part III, Section 4.1).
Records retention requirements are also specified in individual plant procedures and instructions.
4.
Corrective Steps Which Wili Be Taken To Avoid Further Violations No further corrective action is required.
5.
Date When Full Compliance Will Be Achieved Full compliance has been achieved regarding identification of records retention requirements. However, due to the nature of the violation and the reasons and corrective steps described above, it is possible that other records from the early years of plant operation may not meet the requirements of 10 CFR 50, Appendix B, Criterion XVII. The corrective action addressed in this case is considered to be adequate to correct this problem.
Item D - 260/83-27-07 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
. Contrary to the above, this requirement was not met in that the house-keeping checklist requirement included as step 17 of Work Plan 6853 (cable Installation for Unit 2 Scram Discharge Volume) was not completed for all work areas as delineated in Standard Practice 14.3 and 8.3.
Werk activities in the area of panel 25-32 (Unit 2 Backup Emergency Shutdown Control Center) were affected as required by Work Plan 6853 during the recently completed Unit 2 refueling outage and panel 25-32 was not returned to the as canfigured original installation. Examples include:
(1) All control back panels used for moisture and dust protection were not reinstalled after maintenance.
(2) Numerous debris, including plastic shelvet, foam material, trash, and metal clips were found in the cabinet.
(3) Electrical cables were found extended from the cabinets (cables worked in accordance with workplan 6853).
This is a Severity Level V Violation (Supplement I) and applicable to Unit 2.
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted The location of panel 25-32 was inadvertently left Off of the housekeeping checklist. Consequently, cleanup of the panel and panel area was simply overlooked.
3 Corrective Steps Which Have Been Taken and the Results Achieved Cleanup of panel 25-32 was performed to correct the conditions identified by the inspector. Plant procedure Modification / Addition Instruction (MAI)-13, which covers modifications that affect electrical panels, was revised to require additional signoffs for housekeeping while performing a modification.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations A work item has been placed on the outage schedule requiring an inspection of all electrical panels affected by engineering change notices worked during an cutage. The inspection will be performed with a maintenance request following completion of all modification work associated with the outage.
. 5.
Date When Full Compliance Will Be Achieved Full compliance was achieved on August 24, 1983, when MAI-13 was revised to include signoffs for housekeeping checks.
Item E - 259. 260. 296/83-27-12 Technical Specification 3.7.B.1 requires all three trains of the Standby Gas Treatment (SBGT) system to be operable when secondary containment integrity is required except 3.7.3.5 permits one train of the SBGT system to be inoperable for up to seven days.
T.S.4.7.B.3.c requires that when one train of the SBGT system becomes inoperable, the other two trains shall be demonstrated operable within two hours.
T.S.4.7.B.1.a requires each train of the SBGT system maintain 9000 cfm i 10% flow.
T.S.3.7.B.4 states that if these conditions cannot be met, the reactor shall be placed in a condition for which the SBGT system is not required.
T.S.1.0, Definitions, ' requires the unit be placed in at least hot shutdown within six hours when a Limiting Condition for Operation (LCO) or associated requirements cannot be met.
Contrary to the above, the requirements were not met. A and C trains of SBGT were determined to be " operable" at about ~.2:01 a.m., June 14, 1983, using installed flow instrumentation. The installed flow instrumentation was determined to be out of calibration at about 2:45 a.m., June 14, 1983 As a result of previous damper adjustments using the installed flow instrumentation the air flow on A and C trains was out of specification; therefore, A and C trains were inoperable. Units 2 and 3 were not placed in hot shutdown within six hours and the A and C trains of the SBGT system were not demonstrated operable until 11:30 a.m., June 14, 1983 This is a Severity Level IV Violation (Supplement I) and is applicable to all units.
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted The violation occurred because (1) instrument readings that were used to set the proper flows for A and C SBGT trains were incorrect and (2) there was inadequate communication among electrical maintenance, operations, and engineering personnel involved in the tests and repairs.
SBGT train B was out of service for electrical maintenance repair of the relative humidity heater. At approximately 0000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, June 14, 1983, the remaining two SBGT trains A and C were apparently verified operable by operations personnel as required by technical
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. specifications, using station instrument readings to set the discharge damper positions. However, at approximately 0245 hours0.00284 days <br />0.0681 hours <br />4.050926e-4 weeks <br />9.32225e-5 months <br />, the station instrument readings were discovered to possibly be in error by an electrical engineer when test instruments (pitot traverse) used to verify flow on SBGT train B showed the station instruments to be reading too high. However, this information was not related to any licensed personnel, nor to plant management. Discussions between the test personnel and their supervisor did lead to further testing and setting of A and C SBGT train dampers.
-3..
Corrective Steps Which Have Been Taken and the Results Achieved The SBGT train discharge dampers have been distinctly marked at their required positions as set by test instruments. If the dampers are found to be off these preset positions, they will be reset to the correct (marked in red) position. Plant instructions involving SBGT flow rate testing were revised in August 1983 to require that test instruments be used for altering damper position (instead of station instruments).
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations No further corrective action is required.
5.
Dele When Pull Compliance Will Be Achieved Full compliance was achieved on August 16, 1983, when revisions to the appropriate plant instructions were completed.
Appendix B 259, 260, 296/83-27-10 (1) The Browns Ferry Final Safety Analysis Report (FSAR), Section 7.18.2, states that the backup control system shall be designed to:
"Have safety wires on the transfer switches that break whenever the switches are turned from their normal position."
Contrary to the above, the inspector noted that no safety wires are installed on the backup control system transfer switches for any unit.
(2) The Browns Ferry FSAR, Section 7.18.6, states that the backup control center operability will be tested once per operating cycle.
Contrary to the above, no operability test has been approved or conducted to date.
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. This item is applicable to all units.
Item 1 Corrective Actions Which Have Been Taken TVA has reviewed and evaluated the design basis of the backup control system to determine why the transfer switches were described in the FSAR, Section 7.18.2, as having safety wires.
The backup control transfer switches are under administrative control with control room annunciators which alert the operator if any switch is placed in the emergency position. Since the only purpose of the safety wire would be to indicate tampering and possible mispositioning of the transfer switches and since this is accomplished with control room annunciators, there is not a design basis for this statement in the FSAR.
Corrective Actions Which Will Be Taken To Avoid Further Violations The FSAR will be changed to delete the statements that safety wires would be provided on the backup control system transfer switches.
Date When Corrective Action Will Be Completed This corrective action will be completed commensurate with the 1984 FSAR update.
Item 2 Corrective Actions Which Have Been Taken A new technical instruction has been drafted and is in the p2 ant review cycle. This instruction will cover the performance of functional tests of panels 25-32 and 25-31 (backup control center) in sufficient detail to ensure that FSAR requirements are met.
Corrective Actions Which Will Be Taken To Avoid Further Violations No further corrective action is required.
Date When Corrective Action Will Be Completed Full compliance will be achieved by October 12, 1983, when the new technical instruction covering testing of panels 25-32 and 25-31 will have been implemented. The test will be performed on unit 1 during the present refuel outage and during future outages as described in the FSAR.