ML20086R899
| ML20086R899 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/28/1995 |
| From: | Machon R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9508010030 | |
| Download: ML20086R899 (5) | |
Text
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"d Tennessee Valley Authonty. Post Oftce Box 2000. Decatar, Alabama 35609 July 28, 1995 U.S.
Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
)
Docket Nos. 50-259 Tennessee Valley Authority
)
50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - NRC INSPECTION REPORT 50-259, 50-260, 50-296/95 REPLY TO NOTICE OF VIOLATION (NOV)
This letter provides our reply to the subject NOV transmitted by letter from Mark S.
Lesser, NRC, to Oliver D. Kingsley, Jr., TVA dated June 28, 1995.
The NOV involved a failure to test the core spray check valves in accordance with technical specification and American Society of Mechanical Engineers code requirements.
TVA admits this violation. provides our response to the NOV. is a summary of commitments made in this letter.
If you have any questions regarding this reply, please contact Pedro Salas at (205) 729-2636.
Sincerely,
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Machon Site Vice President Enclosure cc:
See page 2 G1CCGG 9508010030 950728 j(((
PDR ADOCK 05000259 D
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2 U.S. Nuclear ~ Regulatory Commission
- ' Page 2 July 28, 1995
..I Enclosure l
cc (Enclosure):
Mr. Mark S.
Lesser, Acting Branch Chief I
U.S. Nuclear Regulatory. Commission i
Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant I
Route 12, Box 637 Athens, Alabama 35611 Mr. J.
F. Williams, Project Manager.
U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 l
4 I
ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 INSPECTION REPORT NUMBER 50-259, 50-260, 50-296/95-31 REPLY TO NOTICE OF VIOLATION (NOV) i i
BESTATEMENT OF.THE VIOLATION Technical Specification 1.0MM.1 requires that inservice testing of ASME Code Class 1, 2,
and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR 50.55a, except where written relief has been granted by the Commission.
The licensee's second ten year interval Inservice Test Program is based on the 1986 edition of Section XI of the ASME Boiler and Pressure Vessel Code.
The 1986 edition, IWV-3522:
Exercising Procedure, states that check valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant operation.
Valves that cannot be exercised during plant operation shall be specifically identified by the Owner and shall be full-stroke exercised during cold shutdowns.
Relief Request PV-25 dated May 2, 1994 stated that the core spray testable check valves will be cycled during each cold shutdown by being stroked full open and full closed using the control room handswitch.
Contrary to the above, inservice testing of the Unit 2 core spray l
testable check valves (2-FCV-75-26 and 2-FCV-75-54) was not performed in accordance with the above requirements, in that they were.not full stroked open during cold shutdown.
This condition was identified on May 15, 1995.
I Thic is a Severity Level IV Violation (Supplement I).
TVA'S REPLY TO THE VIOLATION 1.
Reason For The Violation This violation resulted from a lack of personnel knowledge 1
of the.as-built plant design.
BFN plant personnel assumed that the actuators for these valves were similar to the actuators for other check valves in other systems.
That is, BFN personnel assumed that since the actuators for these check valves rotated 180 degrees, the valve disk fully opened.
However, they did not know that these actuators are
4 1
unique and have an internal disk pin that is offset approximately 150 degrees.
As a result, these actuators only open the valve disk approximately 30 degrees.8 2.
Corrective steps Taken And Results Achieved TVA will reinforce management expectations for system knowledge to appropriate plant personnel (i.e., system engineers).
TVA will also emphasize to these individuals the need to apply a questioning attitude to plant system design and system functions.
TVA expects to complete this action by September 14, 1995.2 3.
Corrective Steps That fHave Been Or1 Will Be Taken To Avoid Eurther Violations TVA will revise the BFN inservice testing (IST) program to incorporate the requirements of ASME/ ANSI Standard OM-10 for testing the Units 1, 2,
and 3 core spray testable check valves.
TVA expects to complete this action by September 14, 1995.
In accordance with the revised program, TVA will test these valves during refueling outages.
For Units 1 and 3, TVA plans to full stroke these valves as part of recovery efforts prior to each unit's restart.
TVA will submit, for NRC review and approval, a new or revised relief request for Units 1, 2,
and 3 to permit partial stroke testing of the CS testable check valves.
TVA expects to submit this relief request by August 31, 1995.2 4.
Date When Full Compliance Will Be Achieved Unit 2 will be in full compliance following NRC approval of the new/ revised relief request, or by the end of the next refueling outage, whichever comes first.
Units 1 and 3 will be in full compliance following NRC approval of the new/ revised relief request, or prior to restart from the current outage, whichever comes first.
'Following identification of this
2This action is not a regulatory commitment.
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ENCLOSURE 2 a
TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2,
AND 3 INSPECTION REPORT 50-259, 50-260, 50-296/95-31 REPLY TO NOTICE OF VIOLATION (NOV)
LIST OF COMMITNENTS t
1.
TVA plans to revise the BFN inservice testing (IST) program to incorporate the requirements of ASME/ ANSI Standard OM-10 for testing the Units 1, 2,
and 3 core spray testable check valves.
TVA expects to complete this action by i
September 14, 1995.
2.
If the new/ revised relief request to permit partial stroke testing of the CS testable check valves is not approved prior to startup from the Unit 2, cycle 8 refueling outage, TVA will exercise the Unit 2 CS testable check valves, in accordance with the applicable code requirements, during this outage.
3.
TVA plans to full-stroke the Unit 3 CS testable check valves i
as part of recovery efforts prior to Unit 3 restart.
4.
TVA plans to full-stroke the Unit 1 CS testable check valves as part of recovery efforts prior to Unit i restart.
.