ML18033B255

Responds to NRC 900309 Ltr Re Violations Noted in Insp Repts 50-259/89-16,50-260/89-16 & 50-296/89-16.Corrective Actions: Contractor Will Perform Another Check Function Review for Mechanical Calculations & Area Walkdowns Will Be Conducted

ML18033B255
Person / Time
Site:	Browns Ferry
Issue date:	04/09/1990
From:	Medford M TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR NUDOCS 9004180336
Download: ML18033B255 (35)

Text

ACCELERATED DISTIUBUTION DEMONSTRATION SYSTEM

~ ~

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ESSION NBR:9004180336 DOC.DATE: 90/04/09 NOTARIZED: NO DOCKET FACIL:50-259 Browns Ferry Nuclear Power Station,'nit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260

• 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee AUTHOR AFFILIATION 05000296'UTH.

NAME MEDFORD,M.O. Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control, Desk)

SUBJECT:

Responds to NRC 900309 ltr re violations noted in Insp Repts 50 259/89 16g50 260/89 16 & 50 296/89 16 CODE: IEOID COPIES RECEIVED:LTR L TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response ENCL

'ISTRIBUTION SIZE:

NOTES:1 05000259 05000260 1 Copy each to: S. Black,D.M.Crutchfield,B.D.Liaw, 05000296 R.Pierson,B.Wilson

~ ~ )

RECIPIENT RECIPIENT COPIES ID CODE/NAME ENCL ID CODE/NAME LTTR ENCL PD 1 1 ROSS,T. 1 1 INTERNAL: ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1 AEOD/TPAD 1 1 NRR SHANKMAN,S 1 NOTES'OPIES'TTR DEDRO NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D 1

1 1

1 1

1 NRR/DOEA DIR 11 NRR/DRIS/DIR 1

1 1

1 1

NRR/DST/DIR 8E2 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OE D 1 1 OGC/HDS 2 1 1 G FILE 02 1 1 RES/DSR/HFB/HFS 1 1 LE 01 1 1 EXTERNAL LPDR 1 1 NRC PDR 1 1 NSIC 1 1 5 5 t

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASFEI CONTACT THE. DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISIRIBUTION LISIS FOR DOCUMENTS YOU DON'T NEEDt TOTAL NUMBER OF COPIES REQUIRED: LTTR 2 ENCL

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0' TENNESSEE VALLEY AUTHORITY 5N 157B Lookout Place APR 0~ 1AAO 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) UNITS 1, 2, AND' NRC INSPECTION REPORT NOS. 50-259/89-16, 50-260/89-16, AND 50-296/89-16 RESPONSE TO NOTICE OF VIOLATION This letter provides TVA's response to the letter from B. D. Liaw to O. D. Kingsley dated March 9, 1990, which transmitted the subject notice of violation. NRC cited TVA with four violations and requested that the response discuss walkdown portions of the return to service process, bounding of the calculation problems, and Unresolved Safety Issue (USI) A-46 implementation.

Enclosure 1 contains TVA's response to the notice of violation. TVA's response to violation A, example 1 discusses how we have bounded the calculation problems noted in the report. The general response to violation B describes how area walkdowns will be used to identify problems such as those noted by NRC. Enclosure 2 contains a description of how hardware and equipment within the scope of USI A-46 is evaluated at BFN prior to program implementation. Enclosure 3 provides a summary list of commitments contained in this letter.

l If you have any questions, please telephone Patrick P. Carier at (205) 729-3570.

Very truly yours, TENNESSEE VALLEY AUTHORITY M. 0. Medford, Vice President, Nuclear Technology and Licensing Enclosures cc: See page 2 0 9004180336 900409 PDR ADGCK 05000259 PDC 9

An Equal Opportunity Employer

o' U.S. Nuclear Regulatory Commission APR 09 1990 cc (Enclosures):

Ms. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 0 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000

0 ENCLOSURE 1 e NOS.

RESPONSE

NRC INSPECTION REPORT 50-259/89-16, 50-260/89-16, AND 50-296/89-16 LETTER FROM B. D. LIAW TO 0. D. KINGSLEY DATED MARCH 9, 1990 Violation A 10 CFR Part 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants," as implemented by TVA's Topical Report TVA-TR75-1, requires under Criterion XVI, that measures be established to assure that conditions adverse to quality be promptly identified and corrected. This criterion also requires

,that the cause of the condition be determined and corrective action be taken to preclude recurrence.

Contrary to the above, for the cases described below, conditions adverse to quality were either not promptly identified or ineffective corrective action was taken to prevent recurrence:

TVA admits each example of this violation. The reason for the violation, corrective steps which have been taken and results achieved, corrective steps which will be taken to avoid further violations, and date when full compliance will be achievedafor each example are discussed below.

~Exam le l Conditions adverse to quality associated with engineering calculations were identified by TVA during engineering assurance oversight of the plant's Design Basis Verification Program and Condition Adverse to Quality Report (CAQR)

BFN880646 was issued on August 4, 1989 to document these deficiencies.

However, corrective actions taken were ineffective in that calculation problems were again identified by TVA during its QA Safety System Functional Inspection dated December 4, 1989 and by the NRC during this inspection.

Recent examples of core spray system (CSS) calculations where errors were identified by the NRC include, (a) CSS piping sizing calculation MD-Q2075-87215, Revision 0, (b) CSS pump net positive "suction head and performance calculation MD-Q2075-87258, Revision 1, and (c) core spray relief valve sizing calculation MD-Q2075-87216, Revision 2.

Reason for the Violation The reason for the errors in the subject calculations was that the check function required by procedures was not rigorously applied to those mechanical calculations identified.

Page 2 of 16 Correct ve Ste s ich H ve Bee aken a d Resu ts c eyed TVA has determined that the calculations containing errors involve inattention to detail and are limited to mechanical, calculations performed by a particular engineering contractor. The contractor has completed a review of selected mechanical calculations to bound the problem, The calculations reviewed were those associated with the preparer and/or the checker of Calculations MD-Q2075-880258 and MD-Q2075-880215. This review confirmed that in some cases the check function was not sufficiently rigorous which was evidenced by a number of minor errors. These errors were found not to impact or alter the conclusions of the calculations.

TVA has investigated the possibility of similar problems existing in the essential calculations of the civil and electrical disciplines as well. The results of this investigation indicate that the problems described in this

.example of violation do not apply to the civil and electrical disciplines.

Specifically, NRC has performed extensive reviews of civil calculations in eleven design areas to date. All open issues from those audits are now closed. Additionally, as a result of .problems identified by an internal electrical discipline audit of electrical/ISC calculations in 1988, a review of essential calculations in those disciplines was performe'd. The findings were tabulated and returned to the originating TVA group or contractor for resolution. While a small percentage of problems remain to be corrected (e.g., removal of unverified assumptions), the majority of the problems identified have been resolved as generally noted by the findings of this inspection.

Cor ective Ste s Which W ll Be Taken to Avoid Further V olations The contractor that performed these calculations has developed a plan to perform another check function review on those calculations developed for BFN Mechanical Engineering. This plan will be a two part program:

a. The contractor will perform another check function review for the mechanical calculations that he prepared, which have not been revised by TVA. The contractor will revise the calculations to incorporate changes as a result of this review.

b. The contractor will also perform another check function review and provide red-lined copies of mechanical calculations originally prepared by the contractor and subsequently revised by TVA. TVA will revise any calculation deemed necessary.

Date When Ful Com liance Will be Achieved Essential mechanical calculations performed by this contractor will be reviewed for errors and the errors corrected. The errors will be evaluated for impact on calculation results and conclusions by August 15, 1990.

0 Page 3 of 16 e ~ggple 2 Conditions adverse to quality associated with the inability to retrieve

'welding and base material records were identified by TVA on Corrective Action Report (CAR) 87-0050. However, corrective action taken was ineffective, in that welding-related records required to be maintained by General Construction Specification G-27, which included certified material test reports for 4 filler metals and 30 base metals and weld data packages for 12 instrument line socket welds, could not be provided to the NRC even after approximately three weeks of searching.

eason for the Violation TVA's corrective actions in response to CAR 87-0050 were inadequate. We did not develop a systematic retrieval method for records generated during original plant construction.

Cor ective Ste s Which Have Been Taken and Results h eyed Subsequent to this inspection, the requested certified material test reports (CMTRs) for the 4 filler metals and 30 base metals were located through discussions between Document Control and Records Management and persons knowledgeable of construction era filing methods. A systematic retrieval method was developed which allows retrieval utilizing a minimum of basic information. To ensure that the retrieval method for the requested CMTRs works, ten welds were selected from the residual heat removal (RHR) system.

Those CMTRs were easily located. This retrieval method has been documented.

Documentation for 12 instrument line socket welds was also requested during the inspection. These socket welds are located outside the drywell. They are TVA Class M and therefore, were exempt from hydrostatic tests and nondestructive examination documentation requirements.

In order to verify that, adequate records do exist where required, TVA researched the records for the core spray instrument lines TI-2-57A-A4 and TI-2-57A-A5. These lines enter the drywell through penetrations X27D and X27C respectively and were required to have detailed documentation. The records for these welds were located and found to be adequate.

Corrective Ste s Which Will Be Taken to Avoid Further Violations The corrective steps described above are adequate to avoid further violations. A sample of records which were required to be maintained have been verified to exist.

Date When Full Com liance Will Be Achieved Full compliance has been achieved.

~Exam la System walkdown of the CSS performed by the licensee on November 5, 1989, in accordance with plant procedure, System Engineering Section Instruction Letter (SESIL) 14, did not promptly identify conditions adverse to quality which included damaged, loose, and missing hardware.

Reason for the Violation Properly trained personnel with the correct sensitivity and threshold for recording deficiencies were not provided to conduct the subject walkdown.

0 Page 4 'of 16 e Cor ect ve Ste s SESIL 14 walkdowns Wh ch Have Been Ta en a d esu ts c ieved provides guidance for system engineers for conducting routine system in accordance with schedules approved by their supervision. TVA has reviewed SESIL 14 and concluded that it is adequate. To increase the attention to detail and lower the threshold for recording deficiencies, TVA has conducted additional field training in the area of walkdowns for system engineers and has increased management attention to the conduct of walkdowns.

Cor e t v Ste s ich Will Be Taken to Avoid Further Violations As described in the general response to violation B, TVA is "going to conduct area walkdowns prior to restart utilizing sufficient trained personnel to identify problems.

Date When Full Com liance Will Be Achieved The area walkdowns will be completed by, August 15, 1990.

10 CFR Part 50, Appendix B, "guality Assurance Criteria for Nuclear Power Plants," as implemented by TVA's Topical Report TVA-TR75-1, requires under Criterion V that activities effecting quality be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with these instructions. Construction installation of safety-related

, hardware, which is a QA activity, was accomplished 'as described below:

dmission or Denial of the Alle ed Violation TVA admits each example of this violation. The reason for the violation, corrective steps which have been taken and results achieved, corrective steps which will be taken to avoid further violations, and date when full compliance will be achieved for each example are discussed below.

This violation consists of multiple cases of failure to follow installation instructions located either on plant mechanical drawings or in the general construction specifications. These deficiencies were due to personnel errors which occurred primarily during original plant construction and prior to this outage. During this outage, TVA has extensively upgraded plant procedures and has communicated to employees management's expectations for performance and accountability.

System engineers have received training on the conduct of walkdowns in order to provide a lower threshold for identification of deficiencies and to increase attention to detail. The system engineers are routinely performing system walkdowns to ensure physical deficiencies are identified and documented so they can be corrected.

Page 5 of 16 Mai'ntenance has conducted training for plant maintenance craft personnel to ensure attention to detail on maintenance activities especially on jobs

,conducted in accordance with the skill of the craft. The BFN Modifications organization has an extensive program in place to strengthen work control activities and to ensure the integrity of the work as described in the general response to Violation C.

TVA is developing a special area walkdown procedure for restart. The area walkdowns are intended to detect existing field deficiencies that resulted past practices. The walkdowns will be performed by a multi-discipline 'rom group that shall consist of at least the following:

System Engineering representative Qualified Operations representative

'Modifications Engineer Civil/Structural Engineer The area walkdowns will be a detailed examination of an area after modification work in the area is complete. Any findings of the walkdown group will be evaluated for impact on suitability of equipment/structures for startup. If any finding impacts operability or compliance with regulatory requirements it will be corrected prior to releasing the area as ready for startup.

In addition to the routine and special area walkdowns, TVA is also committed to a strong System Plant Acceptance Evaluation (SPAE)/System Preoperability Checklist (SPOC) process. During the SPAE/SPOC process for the core spray system, TVA found that the process was uncovering new issues in addition to being a verification of work completion. TVA therefore performed a detailed evaluation of open items on a system-by-system basis. This evaluation looked at drawing discrepancies, change documents, essential calculations, conditions adverse to quality, restart test program items, programmatic punchlist items, design criteria, and primary and critical drawings. This was used to ensure identification of the open items on each system. With the open items identified, the SPAE/SPOC process to be conducted at the time of system return to service will be used to verify closure of open items as intended.

Exam e 1 Drawings 41N734 and 41DS734 required self-locking nuts to be installed on the embedded pump foundation bolts for the CSS and residual heat removal pumps.

Contrary to the above, standard heavy hex nuts were installed.

Reason for the Violation TVA cannot determine why this violation occurred. The subject pumps were installed during initial construction in 1970 and the drawings were as-constructed at that time.

Corrective Ste s Which Have Been Taken and Results Achieved The self-locking nuts were replaced on the embedded pump foundation bolts for the CSS and RHR pumps. All CSS and RHR installations were corrected.

0 Page 6 of 16 Corrective Ste s Which Will be Ta e to Avoid Furt er Violations The installation adequacy of other safety related pumps on unit 2 will be verified during the area walkdowns.

Date When Full Com liance Will be Achieved The area walkdowns will be completed by August 15, 1990.

~Eam le 2 Drawing 48N435 specified structural steel bearing plate anchor fastener details which included installation of bolts, washers and nuts.

f Contrary to the above, several plate anchor installations for the structural

,steel framing at elevation 541'-6" did not conform to the drawing requirements in that washers and nuts were missing and several connections were not tight.

Reason for the Violation This violation was caused, by personnel error during original construction.

Corrective Ste s Which Have Been Taken and Results Achieved One of the discrepancies noted on this installation was a slanted anchor bolt. TVA Civil Engineering has documented in a calculation that the slanted anchor bolt found did not have an adverse impact on plant operability. The other adverse conditions described in this example of the violation have been corrected.

Corrective Ste s Wh ch W ll be T ken to Avoid Further Violations The adequacy of plate anchor installations will be verified during the area walkdowns.

Date When Full Com liance Will be Achieved The area walkdowns will be completed by August 15, 1990.

gxXa~ le 'I Stand-alone Quality Information Notice EEB 821222 901 electrical component mounting details, dated February 4, 1983, specified that all component mounting holes be utilized where possible.

Contrary to the above, Agastat relays located in panel 9-32 and identified as 14A-K123B, 10A-K129A, 10A-K130A, and 10A-K131A which are provided with four mounting holes, were missing one or more mounting bolts.

Reason for the Violation This violation resulted from inattention to detail by personnel performing plant activities.

Corrective Ste s Which Have Been Taken and Results Achieved The missing screws in the subject unit 2 relays were replaced. The units 1, 2, and 3 relay rooms were walked down to look for missing screws on other Agastat relays and no additional missing screws we'e found.

0 Page 7 of 16 0 As described in the general response to Violation B, TVA has trained Modifications, Maintenance, and system engineering personnel on attention to detail to ensure deficiencies such as this do not recur.

Correc ive Ste s Which Wi 1 be Take to void Further Violations

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TVA considers the corrective actions described above adequate to avoid further violations.

Date When Full Com liance Will be Achieved Full compliance has been achieved.

~am pe 4 General Construction Specification G-38, "Installation of Cables Rated Up to 15,000 Volts," and procedure ECI-0-000-LUG-002 require that electrical cable terminations which utilize a mechanical crimp connection be crimped using the proper tools.

Contrary to the above, the termination for the white conductor for cable 2ES3268-II, which supplies power to CSS discharge pressure switch 2-PS-75-35, was not crimped.

Reason for the Violation I

The uncrimped wire was caused by personnel error, apparently during original construction.

Corrective Ste s Which Have Been Taken and Results Achieved The lug was crimped by a maintenance request as a corrective action. Terminal lugs in panel 9-33 (more than 1000 lugs) were inspected and no other cases of uncrimped terminal lugs were found. A search of the Nuclear Plant Reliability Data System (NPRDS) reveals no additional occurrences of uncrimped lugs at BFN. A review of existing procedures used to crimp terminal lugs reveals adequate controls exist to ensure correct installation.

Corrective Ste s Which will be Taken to Avoid Further Violations Because TVA inspected every other terminal lug in panel 9-33 without finding another uncrimped lug, we consider this to be an isolated case and no further corrective actions are necessary.

Date When Full Com liance will be Achieved Full compliance has been achieved.

E~xam le 5 General Construction Specification G-38 and Standard Drawing E12.5.8, detail B, note 78, require that shield wire be protected from inadvertent grounding.

Contrary to the above, the shield wire internal to flow transmitter 2-FT-75-21 was bare and loose and could have resulted in a inadvertent grounding.

Page 8 of 16 for the Violation 0

Reason TVA failed to provide NRC with information from the vendor indicating that the installation was adequate.

Corrective Ste s Which Have Bee Ta en a d esu ts ch eyed The questionable installation was corrected by cutting the shield wire and insulating it with electrical tape. General Construction Specification G-38 provides for this type of restoration maintenance when nonconforming conditions are identified during routine maintenance activities. Maintenance records indicate that there never would have been a need to remove the instrument cover. This explains why maintenance personnel have never identified the discrepancy noted during the audit.

.Corrective Ste s Which W ll Be Taken to Avoid F rther Violations TVA has contacted the instrument vendor who has indicated that the shield wire (ground braid) was intentionally constructed as found during the inspection to facilitate single point grounding and yet maintain the option for grounding at the transmitter if required. Further, the vendor has stated that the braid may be cut off (the conservative action taken when TVA learned of the possible problem), taped back, or left as-is with no effect on transmitter operation.

Since the previous installation is deemed to be acceptable, TVA has determined that no further corrective actions are required for this type of installation.

ate en Full Com liance Will Be Achieved Full compliance has been achieved.

~Exam le General Construction Specification G-40 requires that a wire-protecting device be installed at the, end of a conduit run.

Contrary to the above, conduit wire protection bushings were missing on the conduit junction boxes for panels 25-1 and 25-60 associated with end-devices 2-PS-75-7 and 2-PS-75-16.

Reason for the Violation The violation resulted from personnel error during installation..

Corrective Ste s Which Have Bee Taken and Results Achieved The intent of the requirement for a conduit bushing is to protect the cable during installation (cable pulling). Flexible conduit is installed by pushing it over the cables. This conduit fitting is the type used for termination of flexible conduit and it has a smoother edge than is normally encountered at a rigid conduit end. Inspection of this installation reveals that no cable deformation has occurred. TVA Nuclear Engineering has therefore determined that installation of a conduit bushing in this configuration is not required.

Page 9 of 16 Corrective Ste s Which Wil be Taken to void rther Vio ations or di s Construction specifications and plant installation procedures are already in place which require the use of a bushing at conduit terminations to boxes or other enclosures.

ate When Full Com liance Will be Achieved Full compliance has been achieved.

gxam~l~e Drawing 47M600-46 specified that the floor anchor bolts for floor-mounted instrument racks be 3/4-inch in diameter.

Contrary to the above, all TVA-constructed instrument panels inspected, which included panels 2-25-217 and 2-25-180, were mounted with 1/2 inch diameter bolts.

t Reason for the Violat on This violation has existed since the original construction of determine why this condition exists.

Corrective Ste TVA s Which Have Been Taken and Results Achieved BFN.

Civil Engineering has reviewed General Electric (GE) Report NEDO-10678 "Seismic Qualification of Class I Electrical Equipment" and performed a TVA cannot calculation which verifies the acceptability of the installed 1/2 inch diameter anchors. Procedural controls in place today require discrepancies from drawing requirements to be formally documented.

Corrective Ste s Which Mill be Taken to Av id Fu t e V olations The installation adequacy of the remaining unit 2 floor-mounted instrument panels will be verified during the area walkdowns. TVA Nuclear Engineering will revise applicable BFN design drawings to indicate the use of 1/2 inch diameter bolts where supported by design calculations by July 25,'990.

Date When Full Com liance will be Achieved Full compliance will be achieved by August 15, 1990 when the area walkdowns are completed.

E~xam e Interpretation of radiograph procedure BF-15, Revision 2, which was in effect at the time of construction, requires that the weld and affected base metal meet applicable codes as to wall thickness and weld defects.

t Contrary to the above, radiograph film was evaluated and accepted by the reviewer which included unacceptable base metal wall thickness at weld DCS-2-04 and unacceptable weld defects on weld TCS-2-421.

Page 10 of 16 eason for the Violation The cause of both conditions described above is personnel error. In the case of weld DCS-2-04, the existing requirements for repair of weld defects were not followed. For weld TCS-2-421, the contract radiographer who read the film incorrectly interpreted the O-l sector of the radiograph during installation.

Correct ve St s ich Have een Ta e and Results chieved DCS-2-04 Since the defect was limited to a small area, Nuclear Bngineering evaluated the as-found conditions with regard to the design criteria. An engineering calculation concluded that the pipe weld is acceptable for use as-is.

TCS-2-421 A calculation was performed using fracture mechanic analysis

.techniques and concluded that the weld indications would not grow in size to the extent that design margins would be violated during the life of the plant. It was accepted on a use as-is disposition. TVA is reviewing the other radiographs interpreted by this contract radiographer on the CSS. If any discrepancies are identified, they will be resolved by TVA's corrective action program. During the vertical slice inspection, 25 welds interpreted by

,other radiographers were reviewed and no rejectable weld indications were identified.'n addition, after the vertical slice inspection, a sampling of welds interpreted by other contractors were reviewed by TVA. This sampling consisted of 33 percent of the unit 2 class I HPCI welds which are in TVA's ISI program. No rejectable weld indications were identified.

Corrective Ste s Which Will be Taken to Avoid Further Violations DCS-2-04 The current repair and replacement program contains sufficient safeguards to prevent recurrence. The minimum wall calculation for the core spray system will be revised by May 31, 1990 to show the results of the evaluation of weld DCS-2-04. This weld is part of the Generic Letter 88-01 boundary for intergranular stress corrosion cracking (IGSCC) and is inspected on an established frequency.

TCS-2-421 Qualified TVA radiography personnel currently overview all radiographs interpreted by contract personnel for final acceptance. No further corrective actions are deemed necessary.

Date When Full Com liance Will be Achieved TVA will be in full compliance by May 31, 1990.

Technical Specification (TS) 6.8.1 requires that procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, be established and,implemented. These requirements are implemented, in part, by compliance with the Browns Ferry procedures listed below.

0

Page 11 of 16 e

dmiss on or Denial of the Alle ed Violation TVA admits each example of this violation. The reason for the violation, corrective steps which have been taken and results achieved, corrective steps which will be taken to avoid further violations, and date when full compliance will be achieved for each example are discussed below.

The Modifications Organization presently has an extensive program in place to strengthen work control activities and to ensure integrity of accomplished tasks. Modifications and Addition Instructions and the inspection plan have been consolidated resulting in clearer and better defined procedures.

Workplan data sheets are now more specific and less confusing to the user. A required reading list has been established for modifications engineers, craft

,foremen, general foremen, and management personnel to provide increased familiarity with the p'rocedures that are used to implement work.

Modifications has initiated a comprehensive training program for craft supervision and foremen in order to enhance their supervision skills and to communicate expectations of performance. Emphasis is being placed upon accountability to ensure that each employee understands the value and integrity of his/her signature.

With the accomplishment of these new programs, TVA expects increased productivity and a reduction in conditions adverse to quality. The following are results thus far. The workplan rejection rate has dropped from 10.6 percent to 6.8 percent from mid-February to mid-March. The number of conditions adverse to quality initiated in Modifications dropped from seven in December, 1989 to five in March, 1990 even though the field workforce has increased approximately 30 percent and the volume of production has increased significantly.

E~xam le l Design procedure NEP 3.2, "Design Input," requires that the design output implement the design input, and deviations must be documented. Marathon terminal block vendor's instruction (design input) contained in equipment qualification (EQ) binder BFN 2EQ-TBK-002, specifies termination requirements for certain wire sizes.

Contrary to the above, Design Change Notice (DCN) W0482 A (design output) which involved changing wire size from AWG-10 to AWG-4 for motor-operated valve 2-FCV-75-23 did not implement or evaluate the manufacturer's requirement for terminations. This installation resulted in physical damage to the terminal board and could have resulted in loss of function.

Reason for t e Violation TVA Nuclear Engineering failed to evaluate the consequences of utilizing a larger wire size. Although the salient features of the design (e.g., ampacity rating) were maintained, this design problem (i.e., stiffer cables pushing on terminal block when cover replaced) was overlooked.

0 Page 12 of 16 Corrective Ste s Which ave Bee Ta en nd Results chieved The damaged terminal block in valve 2-FCV-75-23 was replaced and the cables reformed so that the limit switch compartment cover was replaced without contacting the cables.

Nuclear Engineering has confirmed with the vendors of the terminal block and the valve that the application used here is adequate as long as the terminal block's current rating is not exceeded and the installation is properly implemented.

Three MOVs (2-FCV-75-22, -23, and -25) that utilize the Marathon 300 terminal block and a cable larger than iI10 AWG were inspected. Only 2-FCV-75-23 had a damaged terminal. block. There are four other MOVs (2-FCV-74-57, 74-59, 73-26, 73-30) in this category. A preventative maintenance program is in place which

.will inspect wiring, terminations, and connections associated with these valves.

~

EPI-O-OOO-MOV001, "Preventive Maintenance for Limitorque Motor Operated Valves," was revised February 2, 1990 to caution craftsmen to look for degradations which could have occurred as a result of cables extending beyond the boundary of the limit switch compartment.

Corrective Ste s Which Will Be ake to voi urt e Violations TVA Nuclear Engineering will research and document other occurrences of cable upsizing to determine if an increase in wire/cable size could potentially affect other installations in a manner similar to'that of the violation.

Possible problem areas will be field inspected as required and the results documented by July 25, 1990.

The BFN Electrical Engineering discipline will conduct formal training sessions by April 30, 1990 to indoctrinate its personnel in the proper documentation of the basis for changes to vendor recommended practices, specifications, and similar requirements in design packages.

The preventative maintenance inspection on valves 2-FCV-74-57, 74-59, 73-26, and 73-30 will be performed by July 12, 1990.

Date When Full Com liance Will Be Achieved TVA will be in full compliance by July 25,,1990.

gxXam le 2 General Construction Specification G-38 specifies the requirements for cable installation and modifications for safety-related equipment to ensure that the component is capable of performing its function.

Contrary to the above, inspection of containment electrical penetration "EB" and its associated junction box revealed that Raychem splices were improperly installed, bend radii of electrical cables were violated, and cables were not identified.

Reason for the Violation The noted discrepancies were the result of personnel errors and poor workmanship.

0 Page 13 of 16 Corrective Ste s Which Have Been Taken a d esults chieved Maintenance requests have been written to identify and corr ect deficiencies in junction box 2140. TVA randomly selected ten other unit 2 junction boxes and found that they did not have the problems noted in junction box 2140. As described in the general response to Violation C, the plant modifications organization has an intensive program in place to strengthen work control activities and ensure the integrity of accomplished work.

Correc ive Ste s Which Will be Take to Avoid Fu ther Violatio s Adequate procedural controls are in place to prevent recurrence. The specific deficiencies described above will be corrected by May 31, 1990.

ate en Ful Com ian e Wi e Ac eyed TVA will be in full compliance by May 31, 1990.

~mam le Site Director Standard Practice (SDSP) 16.16 Revision 3, "Material Issuance and Return," controls the issuance of material for work on environmentally qualified equipment and requires the proper execution of Material Requisition Form 575.

Contrary to the above, the Form 575 associated with the replacement of a non-EQ terminal board with an EQ terminal board per Work Plan (WP) 2643-89 for devices 2-PS-75-7 and 2-PS-75-16 was annotated as non-EQ and the qualification of the replacement part was indeterminate.

Reason for the Violation This discrepancy is a result of personnel error. The person who filled out the form 575 (requisition form) erroneously checked "non-EQ" on the form. The.

classification listed on the bill of material is what the craftsman uses to decide the EQ requirements. In this example, the bill of material classified the terminal board as "1E LOCA". Because "EQ" was not specifically called out, the craftsman listed the part as "non-EQ".

There was also confusion about the tagging of the terminal board when it was received at Nuclear Stores. The contract on which the terminal board was ordered contained three items. Items 1 and 2 were listed as "EQ" and item 3 was "non-EQ". The terminal board was item 2. At the time of original receipt it appears that Nuclear Stores erroneously tagged items 1, 2, and 3 per the requirements of item 3 (non-EQ). The quality control inspector who verified material and correct tagging also missed the requirement.

0 Page 14 of 16 Cor ectiv'e Ste s Which Have Been Taken and suit c ieved Nuclear Stores has examined each item in the EQ storage area to ensure that the material has the correct EQ label. The terminal board in question was properly tagged. Briefings have been conducted with receiving personnel in the Materials and QA organizations to ensure the tagging requirements are understood and are being met. Actions to ensure material is adequately segregated are completed.

The modifications personnel who initiate forms 575 have been instructed on the requirements for "EQ" and "non-EQ" items and have been cautioned to review the application for which parts are being requisitioned before writing the form 575. The site procedure for material issuance and return was revised to clarify the requirements for identifying EQ parts on the form 575. TVA has verified that an EQ terminal board was installed.

Corrective Ste s Wh c W 1 be The training and procedure revisions described above are adequate to avoid further violations.

Date e u 1 Co iance Will e Achieved Full compliance has been achieved.

gxXam le 4 U WP 2541-88 provided instructions for the removal of wiring to motor-operated valve (MOV) 2-FCV-75-25. Plant procedure SDSP 8.4, Revision 18, "Modifications Work Plans," requires that all work necessary to implement the design change be specified in the work plan.

Contrary to the above, completed WP 2541-88 did not provide explicit instructions for the removal of abandoned unsealed conduit after wiring was removed from environmentally qualified MOV 2-FCV-75-25. This action resulted in negating the EQ of the valve.

Reason for the Violation The workplan was inadequate because of insufficient worksteps and it left too, much interpretation of the drawings up to craft personnel.

Corrective Ste s Which Have Been Taken and Results Achieved The conduit was removed and the motor operator was adequately sealed. TVA randomly selected five workplans which involved the spacing, removal, or abandoning of cables and conduit. No discrepancies similar to that in this violation was found.

The modification organizational structure has been revised so that there is now a single workplan writing group to provide uniform and more detailed instructions to the craft personnel.

Corrective Ste s Which Will Be Taken to Avoid Further Violations This is considered to be an isolated case for which the cause has been corrected. No further corrective actions are deemed necessary.

Page 15 of 16 ate When Full Com liance Will Be Achieved Full compliance has been achieved.

~xam la WP 2541-88 required that electrical grounding straps be installed across non-conductive flexible conduit.

Contrary to the above, no grounding straps were installed across the non-conductive flexible conduit for valves 2-FCV-75-23 and 2-FCV-75-25, even though the WP was signed off as complete.

eason for the Violation This violation was caused by personnel error during- the implementation of workplan 2541-88.

Corrective Ste s Which Have Been Taken a d Results chieved The proper grounding straps have been installed. The engineering and craft 0 personnel involved were interviewed and counselled. TVA has reviewed a sampling of other work performed by these persons without finding other examples of this problem.

Corrective S e s Whic Will Be a e To void Further Violations Further corrective steps are not necessary.

Date When Full Com liance Will Be Achieved Full compliance has been achieved.

Violation D TS 6.8.1 requires that procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, be properly established through technically adequate procedures.

dmission or Denial of the lie ed Violatio TVA admits each example of this violation. The reason for the violation, corrective steps which have been taken and results achieved, corrective steps which will be taken to avoid further violations, and date when full compliance will be achieved for each example are discussed below.

~Exam la l Contrary to the above, core spray Operating Instruction (OI) 75, Revision 14, was not properly established in that the procedure directed postaccident valve manipulation that could have resulted in accident water being diverted to areas outside the contained volume.

In the development of this OI, no consideration was given to radiological conditions beyond a design basis accident.

0 Page 16 of 16 Cor ect ve Ste s ic Have Been Taken and Results Achieved The core spray OI was revised to note that the resetting of primary containment isolation system (PCIS) and restoration of keep-fill water is controlled by 2-AOI-100-1. Procedure 2-AOI-100-1 requires the senior reactor operator's permission to reset PCIS and provides guidance for placing the pressure suppression chamber (PSC) head tank pumps back in service.

TVA has reviewed other operating instructions for steps which could potentially result in contaminated water being diverted to outside the contained volume. This review has resulted in a revis'ion to the RHR operating instruction (OI-74). No other OIs were found to need revision.

Corrective S e s Which Will Be Taken to Avoid Furt er Violations The corrective actions described above are adequate to prevent recurrence.

Date When Full Com liance Will Be eyed Full compliance has been achieved.

E~xam le 2 Contrary to the above, Surveillance Instruction (SI) 4.5.A.l.D(l) was not properly established in that the acceptance" criteria for the system flow values were not supported by calculations and did not ensure that the TS requirements were met.

eason .for the Violation The procedure upgrade process did not ensure that the acceptance criteria were adequately supported by calculations.

Correct ve Ste s Which Have Been Taken and Results Achieved A calculation has been generated by Nuclear Engineering to provide adequate support for the SI acceptance criteria. This new calculation indicates a required discharge pressure approximately 5 psig above that previously used as acceptance criteria. The new values from this calculation have been compared to the most recent performances of 2-SI-4.5.A.l.d (I) and (II) to verify operability. All previous performances of the SIs were evaluated and verified that the system always met the new acceptance criteria at times when operability was required. The unit 2 SIs have been revised to reflect the new values.

Corrective Ste s Which Will Be Taken to Avoid Further Violations Technical Support is coordinating a multi-discipline review of SIs to identify other potential cases where the acceptance criteria is not adequately documented.

Date When Full Com liance Will Be Achieved The review of other SIs, verification of adequate support documentation, and correction of identified deficiencies will be completed by July 11, 1990.

ENCLOSURE 2 N

RESPONSE

UNRESOLVED SAFETY ISSUE (USI) A-46 C Co ce Additionally, several hardware-related items were identified and TVA indicated that resolution of these items would be deferred to resolution of USI A-46, "Seismic Qualification of Equipment in Operating Plants." The NRC staff position on resolution of these hardware items was discussed with your staff during the course of. the inspection and again during the exit meeting. Your response should address how you plan to comply with the staff's position to ensure that non-conforming hardware-related items identified during your system walkdowns are properly evaluated and resolved.

VA's Res onse t

TVA is developing a program for the resolution of USI A-46 consistent with the methodology being negotiated between NRC and the Seismic Qualification Utility Group (SQUG). TVA's letter to the staff dated July 31, 1989 reaffirmed this commitment and established schedules for imP lementation at BFN.

In the interim, for hardware and equipment within the scope of USI A-46 program, BFN's methods can be summarized as follows:

1. Situations where known deficiencies exist that challenge the seismic qualification of the component (e.g., equipment installed without any anchors) are corrected. TVA has previously used this approach with the main control room panels and with the control room emergency ventilation system.

2. Situations where no qualification information exists on the equipment being evaluated are reviewed by a structural/component qualification engineer to ensure that no conditions exist that could adversely affect the seismic adequacy of the equipment. If an assessment cannot verify that the equipment is satisfactory, then a further evaluation will be conducted and the resulting calculation will be used to establish the documentation for seismic qualification.

3. Situations where new equipment is added to existing frames:

A. If a calculation exists, this calculation is updated to show qualification.

B. If a calculation does not exist, a statement in the evaluation calculation for the new installation will be made that the supporting frame is satisfactory. As noted in 2 above, if the assessment cannot be rendered from the field inspection of the frame, a further evaluation will be performed and the resulting calculation will t It should inception.

establish the qualification documentation.

be noted TVA that TVA has been involved with USI A-46 since its personnel are in regular contact with both NRC and industry in this area. TVA's program is consistent with the industry approach. 'xperts

ENCLOSURE 3=

LIST OF COMMITMENTS

1. Essential mechanical calculations performed by the contractor will be reviewed for errors and the errors corrected. The errors will be evaluated for impact on calculation results and conclusions by August 15, 1990 (Violation A, example 1).

2. Area walkdowns will be completed by August 15, 1990 (Violation A, example 3; Violation B, examples 1, 2, and 7).

3. TVA will revise applicable BFN design drawings to indicate the use of 1/2 inch diameter bolts where supported by design calculations by July 25, 1990. (Violation B, example 7).

4. The minimum wall calculation for the core spray system will be revised by May 31, 1990 to show the results of the evaluation of weld DCS-2-04 t

(Violation B, example 8).

5. The preventative maintenance inspection of valves 2-FCV-74-57, 2-FCV-74-59, 2-FCV-73-26, and 2-FCV-73-30 will be performed by July 12, 1990 (Violation C, example 1).

6. TVA will research and document other occurrences of cable upsizing to determine if an increase in wire/cable size could potentially affect other installations in a manner similar to that, of the violation.

Possible problem areas will be field inspected as required and the results documented by July 25, 1990 (Violation C, example 1)".

7. The BFN Electrical Engineering discipline will conduct formal training sessions by April 30, 1990 to indoctrinate its personnel on proper documentation of the basis for changes to vendor recommended practices, specifications, and similar requirements in design packages (Violation C, example 1).

8. Deficiencies in junction.box 2140 will be corrected by May 31, 1990 (Violation C, example 2).

9. The review of surveillance instructions, verification of adequate support documentation, and correction of identified de'ficiencies will be completed by July ll, 1990 (Violation D, example 2).