ML20214G390

Responds to NRC Re Violations Noted in Insp Repts 50-259/87-09,50-260/87-09 & 50-296/87-09.Corrective Actions: base-plate Bolts of RHR SW Pump W/Noted Discrepancy & All Other RHR SW Pumps Retorqued to Ensure Correct Values

ML20214G390
Person / Time
Site:	Browns Ferry
Issue date:	05/18/1987
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8705270051
Download: ML20214G390 (6)

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TENNESSEE VALLEY AUTHOR!TY i

i CH ATTANOOGA. TENNESSEE 374ot l

SN 157B Lookout Place MAY 181987 l

U.S. Nuclear Regulatory Commlssion 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 UNITS 1, 2, AND 3 - NRC OIE INSPECTION REGION II INSPECTION REPORT NOS. 50-259/87-09, 50-260/87-09, AND 50-296/87-09 RESPONSE TO VIOLATION i

l Enclosed is TVA's response to the letter from G. G. Zech to S. A. White dated April 8, 1987, transmitting IE Inspection Report Nos. 50-259/87-09, 50-260/87-09, and 50-296/87-09 which cited TVA with one Severity Level V Violation for TVA's Browns Ferry Nuclear Plant.

Please refer any questions to M. J. May, at (205) 729-3566.

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

[

Very truly yours, TENNESSEE VALL AUTHORITY R. Gridley, Di actor l Nuclear Safet and Licensing Enclosure cc: See page 2 l

- 8705270051 870518 gDR ADOCK 05000259 PDR /h k\

l l An Equal Opportunity Employer l I,

U.S. Nuclear Regulatory Commission MAY 181987 cc (Enclosure):

Mr. C. G. Zech, Assistant Director Regional Inspections Division of TVA Projects Of fice of Special Projects U.S. Nuclear Regulatory Commission Region II 101 Marietta St., NW, Suite 2900 Atlanta. Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant P.O. Box 311 Athens, Alabama 35611 Mr. J. A. Zwolinski, Assistant Director for Projects Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Commission 4350 East West Highway EWW 322 Bethesda, Maryland 20814

. RESPONSE NRC INSPECTION REPORT NOS.

50-259/87-09, 50-260/87-09, AND 50-296/87-09 LETTER FROM G. G. ZECH TO S. A. WHITE DATED APRIL 8, 1987

= Violation Technical Specification 6.3 requires that detailed written procedures covering plant operations shall be prepared, approved and adhered to.

1. Contrary to the above, Mechanical Maintenance Instruction (MMI)-29 RHRSW Pump Inspection and Maintenance, was not adhered to on November 24, 1986.

As documented on Maintenance Request (MR) No. A-706494, the A3 RHRSW Pump basoplate nuts were to be torquod as required by MMI-29, Section B, Step 10.4. Although this step requires that the torque be adjusted between 15 and 1,000 ft-lbs, one of the A3 RHRSW pump nuts was adjusted to a value outside of this range (0 ft-lbs.).

2. Contrary to the above, this requirement was not met in the following Browns Ferry Standard Practice 15.2 Licensee Event Report, for preparing Licensee Reportable Event Determination (LRED) 87.-1-035 in sufficient detail for determining reportability. Unit I reactor building ventilation exhaust continuous air monitor, 1-90-250, failed a low flow alarm test during performance of Surveillance Instruction SI 4.8.B.4-3A for the monthly functional test on 1/16/87 as observed by the inspector.

Excessive in-leakage from a loose orifice flange and a large dead band for the Magnehelic flow gage was determined to be the cause. One of the items to be checked for reportability determination stated on the LRED was a flow check for each CAM. Thirty days after the initial surveillance test no flow checks were conducted. The CAM in-leakage creates the potential for an unmonitored release fren the reactor building.

3. Contrary to the above, Site Standard Practice 2.11, Review, Approval of Site-Generated Procedures / Instructions, requires in part that long-term commitments to organizations outside BFN (such as DQA, NRC, ANI, etc.)

shall be marked in a manner to easily identify the commitment and the test which implements that commitment. When an entire procedure implements a commitment, it is acceptable to denote that commitment in the purpose or scope of that procedure.

Mechanical Maintenance Instruction 157, Inspection, Lubrication, and Replacement of the LPCI MG-Set Couplings and Bearings, does not satisfy the requirements in that the procedure was revised to clarify coupling alignment criteria which was a Licensee Event Report (LER 296/86-11) commitment, but did not denote that commitment within the procedure.

This is a Severity Levol V Violation (Supplement I) and is applicable to all three units.

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! Example 1 Response

1. Admission or Denial of the Allemed Violation (or Finding)

TVA admits this example of violation.

2. Reasons For the Violations (or Findinz) if Admitted f Maintenance Request A-706493 was worked per MMI-29 which requires base 4 bolts of RHR SW pumps to be torqued between 15 and 1,000 ft-lbs. One of l the base bolts was left at 0 ft-lbs., and documented on MMI-29 data sheet.

i i Technical Support Section personnel, who are responsible for adjusting and determining final torque values, made an error in judgment.

3. Co.rrective Steps Which Have Been Taken and Results Achieved

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The base-plate bolts of the RHR SW pump with the noted discrepancy and all of the other RHR SW pumps were retorqued to ensure correct values. A written notice was issued to personnel involved in the improper torquing together with other personnel who may be performing future torquing operstion on these pumps. Additionally, discussions have been held to

ensure an adequate understanding exists with cognizant personnel on how to properly carry out the procedure, j 4. Corrective Steps Which Will Be Taken to Avoid Further Violations (or

) Findings) i  :

)i No further actions will be taken. l l

1 5. Date When Full Compliance Will Be Achieved .

i l Full compliance has been achieved.

4 Example 2 Response

1. Admission or Denial of the Alleged Violation (or Finding) i TVA admits this example of violation.

2. Reasons For the Violations (or Findina) if Admitted t

TVA agrees that the reportability determination was not well documented.

This was a personnel error.

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3. Corrective Steps Which Have Been Taken and Results Achieved _

This inadequate reportability determination was discussed with the Plant Operations Review Section Supervisor and the Plant Manager to ensure an

- adequate understanding exists of information needed for LREDs. Subsequent investigations and reviews have substantiated the determination of nonreportability per 10 CFR 50.72 and 50.73.

The 90-250 continuous air monitors (CAMS) draw air samples from the Reactor 3uilding, Turbine Building, and refuel zone exhaust ducts of each unit. The low-flow alarm test that the inspector observed is performed by closing the sample line valve and observing that the low flow indicating light comes on. Since the sample pump draws air through the path of least resistance, the inleakage through the loose orifice flange is only excessive when the sample lines are isolated. The orifice flange is located downstream of all three monitoring chambers in the CAM, and any flange inteakage occurring during CAM operation would result in a smaller sample being drawn and monitored from the exhaust ducts. The potential for an unmonitored release would only exist with the sample valves closed. Thus, it was believed that nonceportability had been adequately assessed. Maintenance requests were written and performed during the months of January and February 1987 to ensure no loose orifice plates were present on the Reactor Building CAMS.

When subsequent air inleakage problems were discovered, instrument mechanics began working with chemical lab personnel to reseal the CAMS following daily source background filter checks. A special test has been prepared to locate possible leakage out of or into screwed, welded, gasketed, or swaged connections where such leakage is undesirable and to allow for the repair of any leaks found. Vendor information was needed for preparation and approval of the special test and Unreviewed Safety Question Determination. Allowable system test pressures had to be established for the pumps and other internal components.

4. Corrective Steps Which Will Be Taken to Avoid Further Violations (or Findings) l For the near term. TVA is maintaining the CAMS in an operable condition. 1 Adequate replacement parts are not available and must be fabricated. l Long-term plans are to either order new CAMS or to modify the present CAMS for dependability. The 90-250 CAMS produce alarms and have no control function. When a monitor is found to be inoperable, plant technical specificaticas require temporary monitating of the exhaust path.

5. Date When Full Compliance Will Be Achieved Full compliance has been achieved.

e Example 3 Response

1. Admission or Denial of the Alleged Violation (or Finding)

. TVA admits this example of violation. '

2. Reasons For the Violations (or Finding) if Admitted Inadequate communications between the writer of the LER and the maintenance procedure coordinator resulted in the violation. The writer of the LER should have informed the MMI-157 procodure coordinator that the LER would reflect a procedure revision that was in process. However, the general revision to MMI-157 was not performed as a result of the LER event but because the cognizant maintenance engineer had identified the procedure as needing a general upgrade in order to ensure maintenance would properly be performed. This revision to MMI-157 was initiated before the October 23, 1986 event and, therefore, it was not processed as an LER commitment to NRC. As the procedure revision was already in process, LER 50-296/86-11 stated " procedure revisions to correct these deficiencies have been initiated."

The plant perceived the statement in the LER as a statement of fact and not as a long-term commitment as described in SDSP 2.11. TVA's maintenance program is constantly trying to improve procedures and maintenance methods and can change at any time if improvements are applicable to this equipment. Therefore, item 3 was not considered an NRC commitment and will not be identified in MMI-157 as one.

3. Corrective Sters Which Have Been Taken and Results Achieved This violation has been discussed with the p0RS supervisor responsible for writing LERs and with the maintenance manager responsible for the maintenance procedures. This discussion emphasized the need for better coordination on NRC commitments related to procedures to ensure SDSP 2.11 is strictly adhered to.

4. Corrective Steps Which Will Be Taken to Avoid Further Violations (or El_ndings)

SDSP 15.6, " Commitment / Action Item Tracking," will be changed to clarify what TVA considers statements of facts and descriptions of existing programs versus NRC commitments.

5. Date When Full Compliance Will Be Achieved Changos to the procedure will be accomplished by July 1, 1987.

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