ML20101H470

Responds to NRC Re Violations Noted in Insp Repts 50-259/84-23,50-260/84-23 & 50-296/84-23.Corrective Actions: Procedure MMI-6 Revised to Specify Visual Insp of Lash Adjusters & Crankshaft & Connecting Rods

ML20101H470
Person / Time
Site:	Browns Ferry
Issue date:	08/16/1984
From:	Lambert D TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20101H428	List: ML20101H448 ML20101H470
References
NUDOCS 8412280261
Download: ML20101H470 (8)

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s' TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374ot 400 Cy stnut Street Tower II M AUG 20 All : gg August 16, 1984 U.S. Nuclear Regulatory Commission-Region II ATTN: James P. O'Reilly,. Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

Dear Mr. O'Reilly:

Enclosed is our response to R. C. Lewis'-July 16, 1984 letter to H. G. Parris transmitting Inspection Report Nos. 50-259/84-23,

-260/84-23, -296/84-23 regarding activities at our Browns Ferry Nuclear Plant which appeared to have been in violation of NRC regulations. We have enclosed our response to the Notice of Violation. An extension for submitting our response was discussed between Ross Butcher of your staff and Mike Hellums of my staff on August 15, 1984. 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 D. L. Lambert Nuclear Engineer l

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8412280261 841204-PDR-ADOCK 05000259

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An Equal Opportunity Employer.

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• 1 ENCLOSURE CFFICE CF INSPECTION AND ENFORCEMENT REf0RT NOS.

50-259/ 84-23, 50-260/ 84-23, AND 50-294/ 84-23

. DATED JULY 16, 1984

,~ Item 1 Technical Specification 4.9.'A.1.d requires that each diesel generator be given an annual inspection in accordance with instructions based on the manuf acturer's recommendations.

Surveillance Instruction 4.9. A.1.d,

' Diesel, Generator Annual Inspection,' dated January 25, 1984, states that the maintenance performed by mechanical maintenance is outlined in Mechan-ical Maintenance Instruction (MMI-6) and a reference to the manuf acturer's recommendation of scheduled maintenance is given in Electro-Motive Division Maintenance Instruction (N.I.- 1742) for 999 system generating plants.

Contrary to the above, this requirement was not met in that NMI-6 does not address the engine maintenance as recommended by M. I,1742. Examples of this are as follows:

(a) Annual check of lash adjuster settings (b) 500-hour crankshaft check j

(c) 500-hour connecting rod check

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(d) 500-hour piston to head clearance check i

Units 1 and 2 diesels have run times of greater than 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />. This is a Severity Level IV violation (Supplement I) applicable to all three units.

1.

Admission or-Denial of the A11ered Violation 4

TVA admits the violation occurred as stated'.

i 2.

Reasons for the Violation if Admitted l

(a) Annual check of lash adjuster settings:

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- As indicated in the attached letter from the Electro-Motive j

Division of General Motor, to check a lash adjuster means to 4

visually inspect the lash adjuster (inplace) to ensure it has not collapsed and to check the adjustment per steps 1 through 5, under

' adjusting hydraulic lash adjusters. ' The check does not include removal and disassembly, unless of course, the check reveals a need for repair or replacement.

When mechanical inspections were performed as a part of SI 4.9.A.I.d., there was a requirement for visual inspection of the lash adjusters. When SI 4.9.A.1.d. was revised to refer to MMI-6 for maintenance inspections, the visual inspection of lash adjusters was not incorporated into MMI-6 because only conditions, I

such as collapsed or fractured adjusters, would be identified.

It was believed that a f ailed or out-of-adjustment lash adjuster would be detected by the tapping noise it would make. MMI-6 contained a signoff verification for abnormal operating noises in both the monthly and annual inspections.

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-(b)'and-(c) 500-hour crankshaft and connecting rod check:

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Electro-Motive Division indicates in their letter. that the phrase

' inspect crankshaft and connecting rods,' should be taken to mean performing a cursory visual inspection of the crankshaf t and

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connecting rod areas to inspect for obvious conditions, such as broken or loose bolts, bearing distress, cracks, etc.

Maintenance personnel have made this cursory inspection of the crankshaf t and connecting rod areas while performing cylinder liner, piston, and piston oil cooling tube alignment checks.

During these checks the bottom covers are removed, which provides visual accessibility to the crankshaf t and connecting rod area.

However, a specific signoff for the crankshaf t and connecting rod area did not exist because it was believed that the type of conditions identified in Electro-Notive Division's letter would be easily identified by,the craf tsman and this information would be brought to the cognizant engineer's attention.

(d) 500-hour piston to head clearance check:

l TVA f ailed to include this inspection into its maintenance instructions.

3.

Corrective Stens Which Have Been Taken and Results Achieved s

The following corrective actions have been taken:

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(a) MMI-6 was revised and approved on July 20, 1984 to specify a visual j

inspection of lash adjusters.

(b 8 c) MMI-6 was revised and approved on July 20, 1984 to specify a visual inspection of the crankshaft and connecting rods.

~ (d) In the latest revision of M. I.1742, Electro-Motive Division no 4

longer recommends a piston to head clearance check. Therefore, no action will be taken to make this clearance check.

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Corrective Stens Which Will Be Taken to Avoid Further Violations MMI-6 will be revised to include the maintenance recommendations made in Electro-Motive Division's M. I.1742, Revision E.

This will include recommendations made in the attached Electro-Motive Division letter concerning pump replacement. Actual implementation of any NNI-6 revisions based on N. I.1742, Revision E, will depend on procuring and receiving new components.

Electro-Motive Division's service representatives have indicated to mechanical maintenance personnel that they will forward manuf acturer literature revisions to the mechanical maintenance section as they are published.

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In regard to the management control systems which allowed this i

violation to occur, we have the following response i

It appears that some of the items identified in this violation are the

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result of an interpretation that the intent of M. I 1742 was being met through other inspections, such as listening for abnormal noises when running the diesels as opposed to visual lash adjuster inspection and inspecting the crankshaf t and connecting rod area while performing other work without identifying a specific visual inspection for that area. To resolve the uncertainty which can come f rom this type _ of interpretation, mechanical maintenance personnel will be instructed to fully follow manuf acturer's recommendations in regard to the diesels and to obtain clarification from the manuf acturer regarding uncertain interpretations.

5 Date When Full Como11ance Will Be Achieved Full compliance will be achieved by October 5,1984, when NNI-6 has been revised to include the manufacturer's recommendations.

Item 2 10 CFR 50, Appendix B, Criterion IVI, requires that measures shall be established to assure that conditions adverse to quality, such as f ailures, mal functions, de ficiencies, deviations, defective material and equipment, and nonconformances, are promptly identified and corrected. The identi-fication, the cause, and the corrective action taken shall be documented and reported to appropriate levels of management.

Contrary to the above, the requirement was not met in that revision 1 to nonconformance report BFNNEB8403 dated May 12, 1984, was not incorporated into Energency Operating Instruction 36, ' Loss of Coolant Accident Inside Drywell, ' (E0I-36) until June 15, 1984. Revision 1 expanded on the origin-al report dated May 11,1984 (incorporated in E0I-36 on Nky 12,1984), and -

i identified an additional design error for unit 3.

Further, a recommended step for the temporary solution in the event of the loss of the shutdown

- boa'rd room redundant cooling system was to open the outside door to 'the f an l

tow'er when establishing an exhaust path for air flow for the appropriate unit. As stated in the safety evaluation, the analysis was contingent upon opening an access door upstream of the f an and the concurrent opening of the vent tower doors.

(Unit 1 and unit 2 were operating during this period.)

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This oversight was brought 'to the attention of the licensee af ter the inspector's review on June 14,1984, of LER 84-22 dated June 8,1984, which stated that units 1 and 2 were the only units affected by this event.

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

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1 Admission or Denial of the Allemed Violation TVA admits the violation in that the revision to the NCR was processed as stated. _ We would request consideration be given to the safety significance of the required changes as stated in paragraph 2 below.

2.

Reasons for the Violation if Admitted A high priority was placed on incorporating corrective action into units 1 and 2 operating instructions, zWith unit 3 in a refueling outage and with fuel removed from the vessel, loss of its shutdown board room ventilation is a lesser concern. Also, as explained below, the problem with the potential loss of ventilation is less significant on unit 3.

Therefore, revisions to unit 3 operating instructions were given a lower priority.

There are no load-shed logic contacts affecting unit 3 shutdown board room ventilation.

Single f ailure is the only consideration for unit 3, and it would only affect the upper elevation shutdown board room. None of the 4kV boards are located in the upper elevation shutdown board 4

room. The boards located in that room are the 480V shutdown boards 3A and 3B, the 4POV reactor MOV board 3A, and the 250V dc reactor MOV board 3A.

The only load common to all three units fed off these boards is the 250V battery charger 3 ufram shutdown board 3A. Should this 4

charger be lost there is an alternate charger on unit 2, which can be connected to unit 3 battery.

A step in the revised instruction to open the doors to the outside of the f an towers was added only as a refinement. The completed analysis showed the equipment would continue to function satisf actorily for one I

hour before operator action became necessary and that the exhaust port provided would be adequate. The opening of the doors in the fan room (ventilation tower) to the outside was recommended by Engineering Design as an added margin to assure relief of any positive pressurization.

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3.-; Corrective Stoos Which Have Been Taken and Results Achieved j

l The operating procedures were revised to include unit 3 and were issued j

on June 15, 1984. The licensee event report (LER) BFRO-50-259/ 84022 prepared on June 8 was also revised to include unit 3 and issued as LER l

BFRO-50-259/ 84022, Revision 1, on July 20, 1984.

4.

Corrective Steos Which Will Be Taken to Avoid Further Violations An internal tracking program for. electrical maintenance assignment s is in place which will prevent problems of this type. The revision to the emergency operating instruction was being handled on a nonurgent basis.

5.

Date When Full Compliance Will Be Achieved Full compliance was achieved on July 20, 1984 when the LER was revised to include unit 3.

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tet c mye retario ceraral udtas cw:asi:er t c3<sa;e. IWi 0%2H312) SD M:0 June 26, 1904 Icnnessee Talley Authority

)tr. Dale Taylor Stovns Ferry h'uclect Plant P.. O. I, c x 2 00~'

Decatur, A1.

35602

Subject:

DD lbdel '999 Syt.t cri Gtnerating Plcnts DD Scheduled l' lint enance Progra:n MI 1742 Ecy. E (June 1976)

E r oerfge r ry_ Noe l c a r Pl e_nt, TVA

Dear Hr. Taylor:

This is in res.ponse to Mr. Aston's June 12, 1984 letter to Mr. Ed Ralic requentint, clarificction of certain reccceendations within MI 1142.

M1 1742 was critten specifically for DD Model 999 generaticg plent.a in nuclear standby a ervice and is baced upon en anticipated engine running tico of approxir.stely 100 to,200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> per year. As ctated in the introduction to the H1, "It is intended to serve es a guide when establishing raintenance schedules that will : cot the particular requirenenta of individus1 operations, and planned c00no:ic life of the car.ine ad ur.nocicted equip::ent.--- Imcouse operatin6 re- ' r ec.:n t :,

for this cw ipe.ent enn vary, the onintenance proctdurco r.ust

.e rodified to r.uit individual requirce: ento."

Enclosed la a copy of Levicion E (June 1976) of M1 1742 which in ite.clf vill enuer or clarify acce of your quest for.o.

The follca itR r,pecifically addrc0cea ther.t iterr. tientioned in your Jet ter:

1.

Ic h kJjunterc The " Check 1. ash Adjust er" reewaentt i >a 10 f ound on page 7 (Every Year).and on p.nc 14 (Ever y 6,JM/ liours Of Opernt toa) of H! 174 2 Rev. E.

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n loch od,W.ter ecnr. to visuolly inspect the Inah adjra t ur (f u place) to insure it hos not collar. ped end to ched t hr. c dj n.. t n:nt por r.t cpc 1 thrvu;;h $ of the f.niin?

);iint er.unce Mir.ut.l. :;cc t ic.a :.. under "Adjuct iny, Ilydra 2lic 1.s;h Ad.tuaterc". '!he "che::1." does nc.t Include recovnl.

end dic.ic;enbly, ualea : el course, the check revenlc a i

r.n J for repnir or rep!cecicnt.

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}k. Dale Tcylor PaBe 3

.une 26, 1984 W

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Engine Ronning ifee c) 6,000 Houra - Replace Engino 011 Puups. Thio is based pritorily en friction vest cons'.dct-allons and represents approx 1totely one pu;tp repl.iccinent during the anticipated 40 year 31(c of the nucicar plant based on 100 to 200 ent,fnc hours per year.

I tract the.abova providca the clotification you requested.

Regardo,

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M. J. Fleckenutein District Engineer POWF.R PRODUCT SERVICE YJVsees Enclosure ect PJ. James Aston - IVA D. W. Ctfrikoa E. R. )iioneyer

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