ML20237H100
| ML20237H100 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/27/1987 |
| From: | Girdley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8709030118 | |
| Download: ML20237H100 (6) | |
Text
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c TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 374ot l
SN 157B Lookout Place AUS 271987 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 centlemen:
In the Matter of the
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260
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50-296' BROWNS FERRY NUCLEAR PLANT UNIT 1, 2. AND 3 - NRC OIE INSPECTION REPORT NOS.
50-259/87-26, 50-260/87-26, AND 50-296/87 RESPONSE TO VIOLATION Enclosed is TVA's response to the letter from G. G. Zech to S. A. White dated August 5,1987, transmitting IE Inspection Report. Nos. 50-259/87-26,
~50-260/87-26, and 50-296/87-26 which cited TVA with one Severity level IV violatic.. Our response to the violation is given in enclosure 1.
A list of commitments is given in enclosure 2.
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 complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY 1 '
R. Gridley, D ector l
Nuclear Safe and Licensing f
f Enclosures cc: See page 2 l
870903011O B70827' PDR ADOCK 05000259 g 8[
G PDR An Equal Opportunity Employer If g
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U.S. Nuclear Regulatory Commission
/\\US 271987 cc (Enclosures):
Mr. J. A. Zwolinski, Assistant Director For Projects Division of TVA Projects Office of s8pecial Projects U.S. Nucicar Regulatory Commission 4350 East West Highway EWW 332 Bethesda, Maryland 20814 Mr. G. G. Zech, Assistant Director Regional Inspections Division of TVA Projects office 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
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ENCLOSURE 1
RESPONSE
BROWNS FERRY NUCLEAR PLANT (BFN)
NRC INSPECTION REPORT NOS.
50-259/07-26, 50-260/87-26, AND 50'-296/87-26 LETTER FROM G. G. ZECH TO S. A. WHITE DATED AUGUST 5, 1987 Violation 10 CFR SC, Appendix B, Criterion XVI requires that measures shall be established to assure that conditions adverse to quality such as failures, malfunctions and deficiencies are promptly identified and corrected.
For significant condition adverse to quality (SCAQ) the measures shall assure that the cause of the condition is determined and corrective action is taken to preclude repetition.
he SCAQ, the cause, and corrective action shall be reported to appropriate levels of management.
Contrary to the above, the following requirements were not met after identification of an SCAQ related to the failure of emergency diesel room fire dampers on March 3, 1987.
1.
Although the root cause of fire damper failure was attributed to excessive dust accumulation on the damper blades, the dust was not removed from the dampers. The SCAQ was therefore not corrected.
2.
As of June 15, 1987, neither the Plant Operations Review Committee nor the Plant Maintenance Superintendent reviewed the March 16, 1987, failure investigation report which documented the root cause and corrective action recommendations. The SCAQ was therefore not reported to appropriate levels of management.
3.
No closure or tracking mechanism existed for corrective action recommendations documented on the failure evaluation. Thus, corrective action to preclude repetition was not taken in a timely manner.
This is a Severity Level IV Viointion and is applicable to all 3 Units.
Example 1 Response 1.
Admission or Denial of the violation TVA admits this example of the violation with one correction.
The root cause of the fire damper failures was attributed to a " collection of dust" rather than " excessive dust accumulation on the damper blades."
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Reason for the Violation The fire protection engineer who verified emergency maintenance on the fire dampors also wrote the failure investigation reports. He determined that the dust buildup on the damper pivot arms at the sealed bearings due mainly to' previous lubrications and infrequent cycling was the cause of the failure.
The dust on the damper blades was determined to be insignificant and was not removed. The root cause description in the failure investigation attributed the failure to a collection of dust and was, therefore, not specific enough.
3.
Corrective Steps Which Have Been Taken end Results Achieved A Condition Adverse to Quality Report (CAQR) was initiated to identify the CAQ described in this example of the violation and expedite the corrective actions to prevent recurrence.
The fire damper failure' investigation reports have been revised to correctly attribute the' fire damper failures to accumulations of dust on the damper pivot arms at the sealed bearings due mainly to previous lubrications and infrequent cycling.
The fire damper f ailures were corrected and operability was verified by a member.of the BFN Fire Protection Unit.
4.
Corrective Steps Which,Will Be Taket to Avoid Further Violations
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The BFN Fire protectica1 Unit itsyritin5 a preventive maintenance program for the emergencyfdiesel room fica dampers 5thich will ensure that the y-c; ' dampers are fret of dutt, lubricated,' manually cycled, and checked for 1
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operability on s' periodic basis.
The maintenance' program will also address the type of lubricant to use and the correct damper linkage settings.
c, 5.
Date When Full Compliance Will Be Achieved
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The preventive maintenance program for the emergency diesel room fire dampers,elli be implemented by October 1, 1987.
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Examples 2 ant 3 Response I
1.
Admission or Denial of the Violation
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TVA admits theso examples of the vioJntion.
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Retsons fi Lth'e 3!iolation m
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Thebo. was no MEK /mantgement control in' place to ensure f ailure
. investigation review 1 by either the Plant Operations Review Committee or the Maintenance Superintendent.
There was no mechanism at BFN to track Callure investigation recommendations.
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Corrective Steps Which Have Been Taken and Fesults Achieved j
A CAQR was initiated to identify the CAQs described in these examples of the violation and expedite the corrective actions to prevent recurrence.
I BFN Plant Maintenance Instruction 6.13. " Failure Investigation of Safety-Related Items," has been revised. This procedure requires:
~(1) The Maintenance Superintendent / designee to review the investigation report for completeness and acceptability of the recommendation, and (2) The failure investigation to remain open until recommendation.e and corrective actions are completed or.dispositioned.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violation None 5.
Date When Full Compliance Will Be Achieved f
Full compliance has been achieved.
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e ENCLOSURE 2 LIST OF COMMITMENTS MADE IN ENCLOSURE 1 4
1.
The preventative maintenance program for the emergency diesel room fire dampers will be implemented by October 1, 1987.
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