ML20147A871
| ML20147A871 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/11/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8801150085 | |
| Download: ML20147A871 (9) | |
Text
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA, TENNESSEE 37401 I
SN 157B Lookout Place JAN 111988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-259 i
l Tennessee Valley Authority
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50-260
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50-296 i
BR0HNS FERRY NUCLEAR PLANT (BFN) UNITS 1, 2, AND 3 - HRC INSPECTION REPORT N05. 50-259/87-33, 50-260/87-33, AND 50-296/87-33, - FESPONSE TO NOTICE OF VIOLATION This letter is to provide TVA's response to your letter from G. G. Zech.to S. A. White dated November 19, 1987, which transmitted the subject inspection report. This report cited TVA with three violations.
(
! provides background information and TVA's response to the l
violations, A list of commitments is provided in enclosure 2. He do not recognize any-other items described herein as commitments.
A' Mtension of the response due date until January 11, 1988 was agreed to by A.
..iaton's in a telephone call on Lacember 2i. 1987.
l A letter from X. P. Barr to S. A. White dated December 3,1987 transmlirg inspection report 87-37 requested TVA to respond to NRC concerns about management control and involvement in the area of special testing.
These coacerns are addressed in enclosure 3.
If you have any questions, please telephone Clark J. Madden (205) 729-2049.
Very truly yours, TENNESSEE VALLEY AUTHORITY n-R. G idley, Di c
Nuclear Licensing and Regulatory Affairs Enclosures c r. :
See page 2
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An Equal opportur.ity Employer t-
... U.S. Nuclear Regulatory Commission gg cc (Enclosure):
Mr. G. G. Zech, Assistant Director for Projects Mail Stop 7E23 Division of TVA Projects -
Office of Special Projects U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Mr. K. P. Barr, Acting Assistant Director for Inspection Programs TVA Projects Division Office of Special Projects U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NH, Suite 2900 Atlanta, Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 12, P.O. Box 637 Athens, Alabama 35611
,s ENCLOSURE 1
RESPONSE
NRC INSPECTION REPORT NOS.
50-259/87-33, 50-260/87-33, 50-296/87-33 LETTER FROM G. G. ZECH TO S. A. WHITE DATED NOVEMBER 19, 1987 Violation A l
Orders issued to the licensee on March 23, 1983, relating to NUREG-0737 action items require that the licensee implement and maintain specific NUREG-0737 items described in the attachments thereto no later than the dates or fuel cycle numbers shown in the attachments.
Included in these attachments is the requirement to install Containment High Range Radiation Monitors (NUREG-0737, Item II.F.1.3) for unit 2 prior to startup in Cycle 6.
10 CFR 50, Appendix B, Criterion III requires that measures be established to assure that applicable regulatory requirements and design basis are correctly translated into specl#1 cations, drawings, procedures, and instructions.
Contrary to the above, the licensee failed to establish measures to assure that the regulatory requirements of NUREG-0737, Clarification of TMI Action Plan Requirements for the Containment High Range Radiation Monitoring System (CHRRMS) were correctly translated into specifications, procedures, and instructions based on the following examples:
Example 1 NUREG-0737 requires that the CHRRMS be located to view a large segment of the containment atmosphere which will accurately reflect and monitor accident conditions.
The monitors must be widely separated so as to provide independent measurements and shall view a large fraction of the containment volume.
At the time of the inspection, no engineering calculation existed nor was any documentation available to justify the acceptability of the location selected for the detectors.
1.
Admission or Denial of the Alleged Violation TVA denies this violation.
2.
Reasons for the Denial l
We have carefully reviewed this example and disagree that a violation exists.
NUREG-0737 does not require calculations to justify the loc 1 tion of CHRRMs.
Rather, the requirements are stated in very general terms by specifying that the monitors be placed to view "a large fraction" of the containment volume, that they be "widely separated so as to provide independent measurements," and that they be placed in a manner "to provide a reasonable assessment" of area radiation.
Accordingly, TVA does not l
believe that specific calculations are required to justify the location of the detectors in order to meet the provisions of NUREG-0737.
, During'the design of the CHRRM system, TVA engineering personnel assessed item II.F.1.3 and translated the regulatory requirements for detector location onto design output drawing 47H600-212.
This drawing specifies that the monitors be installed approximately 160* apart in a large open area inside the drywell. He maintain this placement of the CHRRM detectors fully meets NRC requirements.
Examole 2 Although the function of the CHRRMS is to detect and verify a breach of the reactor coolant pressure boundary and to assist in determining the magnitude of radioactive material releases, no design output documents existed which would have integrated these functions into plant procedures.
No changes were required of the Radiological Emergency Plan (REP) to recognize the existence of these monitors.
No emergency action levels were assigned to this monitored parameter nor were the accident assessment sections of the REP required to be changed to utilize information provided by the CHRRMS.
1.
Admission or Denial of the Alleged Violation TVA denies this violation.
2.
Reasons For the Denial The design output document for the High Range Radiation Monitors is Engineering Change Notice (ECN) P0324.
This ECN has been issued and reviewed by affected plant sections.
Existing administrative procedures currently require review of ECNs and resultant modifications to ensure applicable plant instructions are changed as appropriate.
Specifically, Browns Ferry Standard Practice 8.3 requires this coordinated review of modification work packages to determine necessary changes to instructions.
This standard practice does not require affected procedures l
to be revised until the field work is complete and prior to declaring the new installations operable.
Additionally, REP implementing procedures are periodically reviewed and are also checked during emergency drills.
This provides additional confidence that REP procedures are maintained up-to-date and will identify any required changes not captured during the Standard Practice 8.3 review cycle.
NRC issued confirmatory orders by a letter from Domenic B. Vassallo (NRC) to Hugh G. Parris (TVA) dated March 25, 1983, which required these 1
monitors to be installed before startup of cycle 6 for each unit.
Presently, the unit 2 monitors are in the process of being installed and tested.
Because the unit 2 monitors are not declared functional it should not be expected that the applicable unit 2 REP implementing instructions would be revised.
It is noteworthy that the CHRRMs have been previously installed on unit I and are uniquely identified as a recorded plant parameter reading in REP Emergency Plan Implementing Procedure (EPIP) 20.
, Example 3.
'NUREG-0737 requires that the monitors must be accurate.enough to provide-usable information.
No design documentation existed that provided the engineering judgments or calculations used by the licensee in establishing a required accuracy for the CHRRMS.
1.
Admission or Denial of Violation (or Finding)
TVA dentes this example.
2.
Reason for the Denial In a letter dated May 7, 1985 from J. A._Domer (TVA) to D. B. Vassallo (NRC), TVA gave the accuracy of the monitors as being within 36 percent of input radiation. Additionally, the letter stated that range, accuracy, display and instrument location will be in accordance with Regulatory Guide 1.97.
The system accuracy requirements are defined in table 2 note 7 of the_ Regulatory Guide as being a factor.of two over the entire operating range.
Design translated these accuracy. requirements into procurement documents for the instruments.
The vendor designed and qualified the system to meet these requirements.
Therefore, the accuracy requirements were drawn directly from licensing documents and are adequately supported.
Violation B 10 CFR 50, Appendix B, Criterion V requires that activities affecting quality shall be accomplished in accordance with plant drawings.
Plant drawing 458891-1 provides information on electrical conduit sealing and note four of the drawing specifies sealing around cables inside conduits to keep water from entering electrical termination compartments.
Contrary to the above, this requirement was not met for the sealing of electrical conduit as required by plant drawing 45B891-1.
After an inadvertent initiation of the fixed spray fire protection system on August 31, 1987, two of the scram discharge instrument volume instruments (3-LE-85-45J and 3-LE-85-45L) were found full of water.
The conduit leading to the instruments was not sealed at the conduit opening leading from the respective cable tray. Conduit sealing problems were identified during a l
previous initiation of the fixed spray system as detailed in inspection j
report 86-16.
l This is a Severity Level IV Violation (Supplement I).
1.
Admission or Denial of the Violation TVA admits the violation.
6 I
, 2.
Reason for the Violation Drawing 45B891-1 is referenced by conduit drawings 45N802-1 and 2 which were issued with Engineering Change Notice-(ECN) P0392.
The subject conduit (3S6-1064) was installed on June 11, 1984 without water seals to protect the two level instruments.
This installation was performed per the 45N802-2 conduit drawing which had notes making reference to water sealing.
The root cause of the conduit not being sealed was a lack of full understanding over the designers' intentions for installations in accordance with notes 9 and 11 of drawing 45N802-2.
3.
Corrective Steps Which Have Been Taken and Results Achieved Site Directors Standard Practice (SDSP) 8.4 was issued on June 6, 1986 to provide a better method of implementing modifications at BFN.
This new standard practice requires coordination walkdowns between the design engineers and field implementation personnel before the design organization can issue an approved ECN or Design Change Notice (DCN).
Any questions or comments are then resolved between design and the field personnel before a final ECN or DCN Review Package is issued for implementation.
This new ECN/DCN process is now in effect and should preclude further occurrences of this instance since the focus of attention is on ensuring clear communication between the designer and the installer before the ECN is approved to work.
After the inadvertent initiation of the fixed spray fire protection system on August 31, 1987 Maintenance Request (MR) 753469 was issued to reseal junction boxes and panels in the area of the fire protection spray.
The only conduit found not sealed was 35G-2064.
A review of field installations is in progress to identify and fix conduit seal problems. A Condition Adverse to Quality Report (CAQR) has been written to track the resolution of generic concerns of electrical conduits not being sealed in locations designated by design drawings, b
4.
Corrective Steps Which Will be Taken to Avoid Further Violations This violation and related CAQRs will be discussed with design engineers and installation-engineers.
These discussions will omphasize that future similar points of misunderstanding result in better communications between the design concept and the final field configuration. Any necessary corrective actions identified during walkdowns, drawing reviews or otherwise identified to disposition related CAQRs will be completed by April 1, 1988.
Drawing 45N802-2 notes will be clarified where needed in accordance with the Field Change Request (FCR) procedure.
5.
Date When Full Compliance Will Be Achieved April 1. 1988.
I
, Violation C 10 CFR 50, Appendix B, Criterion XVII requires that quality assurance records be maintained to furnish evidence of activities affecting quality and be retrievable. Also, the Site Directors Standard Practice 2.5, Quality Assurance Records, which implements Nuclear Quality Assurance Manual Part III, Section 4.1 requires a lifetime retention for special tests.
Contrary to the above, this requirement was not met in that the Plant Operations Review Committee approved copy of Special Test 87-23 performed on June 26, 1987, could not be located. A further search by the licensee revealed additional missing records.
This is a Severity Level IV Violation (Supplemen' :) and is applicable to units 1 and 2.
1.
Admission or Denial of the Violation l
TVA admits the violation.
2.
Reasons For the Violations Special tests were not being handled as Quality Assurance (QA) records.
Custody for control of special test had been given to the plant Technical Support Services organization since their engineers wrote and conductea the majority of special tests at BFN.
3.
Corrective Steps Which Have Been Taken and Results Achieved Special Test 87-23 was reconstructed from a copy maintained by the test engineer.
This copy was administratively designated as an "official copy".
The results of the test and this document were re-presented to the Plant Operations Review Committee (PORC) for review and plant manager approval. The approved copy has been transmitted to Document Control for safe keeping.
Condition Adverse to Quality Report (CAQR) 8FN870844 was written to document the subject violation, j
Plant procedures PMI 17.1 (Conduct of Testing) and SDSP 2.11 have been revised to place special tests under administrative control of the plant procedures staff.
This requires that the completed records be designated I
and handled as QA records.
1 4.
Corrective Steps Which Will Be Taken to Avoid Further Violations Technical Support Serv.ces will review special tests on file to ensure I
that the records are complete.
Completed test results will be formally transmitted to Document Control for storage.
5.
Date When Full Compliance Hill Be Achieved March 30, 1988.
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, ENCLOSURE 2
RESPONSE
NRC INSPECTION REPORT-NOS.
50-2S9/87-33, 50-260/87-33, 50-296/87-33 LETTER FROM G. G. ZECH TO S. A. HHITE DATED NOVEMBER.19, 1987
. LIST OF COMMITMENTS Violation A None Violation B Discussions will be held on this specific subject with design and implementation engineers to better ensure that future similar points of misunderstanding result in better communications.
This-will be complete by.
February 1, 1988.
Corrective actions will.be completed to disposition related CAQRs by April 1, 1988.
Violation C Technical Support Services will review the special tests on file to ensure that records are complete by March 30, 1988.
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ENCLOSURE 3
RESPONSE
NRC INSPECTION REPORT NOS.
50-259/87-37, 50-260/87-37, 50-296/87-37 LETTER FROM K. P. BARR TO S. A. WHITE DATED DECEMBER 3,1987 The TVA Nuclear Quality Assurance Manual Section 4.6 prescribes the requirements for special test review and performance.
Each special test must have a 50.59 evaluation, PORC review, and Plant Manager's approval before performar:e.
In addition, the test results must be resubmitted to PORC and the Plant Manager.
These requirements are implemented at BFN in Plant Manager Instruction (PMI) 17.1.
(Conduct of Testing) for both safety-related and nonsafety-related activities.
Plant management believes that all unique activities conducted onsite should be reviewed by PORC and approved by the Plant Manager.
This is not believed to dilute management's performance since only an average of 22 special tests are conducted each year.
Instead, management's awareness and involvement in this type of activity is increased.
Special tests, unlike surveillance tests are not performed on a routine basis.
Unfamiliarity with the unique administrative details of PHI 17.1 is the root cause for the problems stated in inspection reports 87-33 and 87-37.
The special test program in PMI 17.1 has been revised to more closely resemble the surveillance instruction program with which the performers of special tests are familiar.
This will minimize the probability of recurrence.
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