ML18033B483

Responds to NRC Re Violations & Deviations Noted in Insp Repts 50-259/90-18,50-260/90-18 & 50-296/90-18. Corrective Actions:Craft Foreman Suspended for Three Days & Relieved of Duties as Foreman

ML18033B483
Person / Time
Site:	Browns Ferry
Issue date:	08/13/1990
From:	Medford M TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9008160213
Download: ML18033B483 (14)

Text

ACCELERATED DlSTRIBUTlON DEMONSTRATlON SYSTEM REGULATORY ZNFORMAT1ON DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR':9008160213 DOC.DATE: 90/08/13 NOTARIZED:

NO DOCKET FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 t

50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION MEDFORD,M.O.

Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 900713 ltr re violations

& deviations noted in Insp Repts 50-259/90-18,50-260/90-18

& 50-296/90-18.

DISTRIBUTION CODE:

ZE01D COPlES RECEIVED:LTR I

ENCL Q SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:1 Copy each to: B.Wilson,S.

BLACK 1 Copy each to: S.Black,B.WILSON Copy each to:

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Black,B.WILSON 05000259 05000260 05000296 RECIPIENT ID CODE/NAME PD COPIES LTTR ENCL 1

1 RECIPIENT ID CODE/NAME ROSS,T.

COPIES LTTR ENCL 1

1 INTERNAL: ACRS AEOD/DEIIB DEDRO NRR SHANKMAN,S t

'NRR/DOEA DIR 11 NRR/DRIS/DIR NRR/PMAS/ILRB12 REG FILE 02 EXTERNAL: LPDR NSIC 2

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1 AEOD AEOD/TPAD NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D NRR/DST/DIR 8E2 NUDOCS-ABSTRACT OGC/HDS2 RGN2 FILE 01 NRC PDR 1

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1 NOTES:

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NOTE TO ALL"RIDS" RECIPIENTS:.

PLEASE HELP US TO REDUCE WAS'ONTACTTHE DOCUMENI'ONTROLDESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISIS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 29 ENCL 29

0,

TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 6N 38A Lookout Place AU8 19 1990 U.S. iVuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.C.

20555 Gentlemen:

In the iMatter of Tennessee Valley Authority Docket Nos. 50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) UNITS 1; 2, AiVD 3 iVRC INSPECTION REPORT NOS. 50-259/90-18, 50-260/90-18, AND 50-296/90-18

RESPONSE

TO NOTICE OF VIOLATION AND NOTICE OF DEVIATION This letter provides TVA's response to the notices of violation and deviation contained in the subject inspection report transmitted by letter from Bruce A. Wilson to 0.

D. Kingsley, Jr., dated July 13, 1990.

The report cited TVA with one Severity Level IV violation for failure to control modification activities and one deviation from commitments made by TVA regarding BFN's program for the handling of drawing discrepancies.

Enclosure 1 contains TVA's response to the violation.

Enclosure 2 contains TVA's response to the deviation.

A list of commitments made in this submittal is contained in Enclosure 3.

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 q008160213 900802 pDR

@DOCK 050 p<U G

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An Equal Opportunity Employer

U.S. Nuclear Regulatory Commission cc (Enclosures):

Ms. S.

C. Black, Deputy Director Project Directorate II-4 U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike, Rockville, Maryland 20852 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637

Athens, Alabama 35609-2000 Thierry M. Ross, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 208 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

ENCLOSURE 1

RESPONSE

NRC INSPECTION REPORT NOS. 50-259/90-18, 50-260/90-181 50-296/90-18 LETTER FROM B. A. WILSON TO O.

D.

KINGSLEY% JR.

DATED JULY 13$

1990 During the Nuclear Regulatory Commission (NRC) inspection conducted on Nay 19-June 18,

1990, a violation of NRC requirements was identified.

The violation involved failure to comply with procedures for controlling modification work activities.

The violation is listed below:

Technical Specification Section 6.8.1, Procedures, requires that written procedures shall be established, implemented and maintained covering applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Appendix A of Regulatory Guide 1.33 includes administrative procedures and procedures for controlling repair activities of safety-related equipment.

Site Directors Standard Practice 7.9, Integrated Schedule and Work

'Control, Section 6.4.1, requires that prior to commencing modifications work activities that have the potential for affecting equipment operation which may affect the safe operation of the unit, that documented approval be obtained from plant operations personnel.

Contrary to the above, on Nay 29, 1990, prior documented approval from plant operations was not obtained before modifications personnel began disassembly of a piping support affecting a portion of the operating north EECM header.

The activity resulted in the failure of a Dresser coupling, resulting in that source of cooling water supply being inoperable.

This resulted in the movement of an 18 inch header, and the discharge of large amounts of water in the piping tunnel with personnel in the tunnel.

l.

Admission or Denial of the Alle ed Violation TVA admits that the violation occurred.

2.

Reasons for the Violation This violation occurred as a result of personnel error.

The modifications foreman directing the work effort failed to recognize that authorization to implement the north header portion of workplan 0084-90 had been denied.

On May 29, 1990, Modifications Steamfitters were implementing Design Change Notice (DCN) W7630 per Hodification Morkplan 0084-90.

The work activity involved the replacement of a support in the 18-inch Emergency Equipment Cooling Mater (EECW) north header piping at the penetration between the Residual Heat Removal (RHR) service water tunnel and the'nit 3 reactor building.

Upon removing bolting from the support, piping separated at a coupling (Dresser) located just upstream of the work area.

Separation occurred as the last through bolt was cut at the Dresser coupling, resulting in pipe displacement of approximately 2-3/8" into the unit 3 reactor building.

Enclosure 1

Page 2 of 2

At the time of the event, the EECW north header was in service, but was not considered operable in accordance with the BFN Technical Specifications.

The EECW system was operating at approximately 125 psi and at a flow rate of 2000 gpm.

The piping separation resulted in flooding in the service water tunnel.

The craftsmen immediately exited the flooding service water tunnel without injury and notified Operations.

The Modifications organization scheduled the workplan for implementation with the Work Control Center.

The request solicited authorization to work hanger modifications on both the north and south EECM headers.

However, the Work Control Center Operations representative authorized work on three specific hangers on the south header only.

This limitation was identified in the Impact Evaluation Sheet (IES).

The modifications foreman obtained and signed the IES, but remained unaware that the authorization restricted work to the south header only.

3.

Corrective Ste s Which Have Been Taken and Results Achieved The craft foreman was suspended for three days and was relieved of his duties as a foreman.

Based on calculations of piping and support stress levels experienced during the separation transient, TVA has determined that support loads did not exceed design allowables.

The pipe stresses were within code allowables with the exception of a weldolet attachment of a 3" diameter pipe to the 18" diameter header.

Visual examination of other supports revealed no abnormal condition or damage.

The Dresser coupling sustained no damage and was reinstalled after gasket replacement.

During a weekly safety meeting this incident was discussed with all modifications craftsmen.

4.

Corrective Ste s Which Will be Taken to Avoid Future Violations None 5.

Date When Full Com liance Mill Be Achieved The physical replacement of the 3" weldolet will be completed by August 17, 1990.

ENCLOSURE 2

RESPONSE

NRC INSPECTION REPORT NOS. 50-259/90-18, 50-260/90-18, 296/90-18 LETTER FRON B. A. WILSON TO O.

D.

KINGSLEY1 JR.

DATED JULY 13, 1990 The following deviation was identified during the inspection conducted on Nay 19-June 18, 1990.

The licensee stated in a letter to the NRC dated February 7,

1989 that drawing discrepancies initiated after November 4, 1988 against Unit 2 primary or critical drawings would be required to be closed within 30 days of receipt by Nuclear Engineering.

Contrary to the above, a listing of 1989 Unit 2 restart primary and critical drawings on Hay 24, 1990 found only 61 of 127 closed.

The average time the 127 DDs were open was 269 days.

An example was DD-2-89-0250 designated a primary Unit 2 restart DD on August 27, 1989.

The description of the DD was that the connection designations for the control rod insert and withdraw block relays do not agree.

No action had been taken to resolve the DD as of Nay 24, 1990.

1.

Admission or Denial of the Alle ed Deviation TVA admits the deviation.

2.

Reason for the Deviation The deviation occurred as a result of an inconsistent and administratively inefficient procedural process for the handling of drawing deficiencies.

This program required that all drawing deficiencies be processed by the Nuclear Engineering (NE) organization for review and disposition even if no iVE action was required.

For

example, the program required NE involvement in the resolution of drawing discrepancies where the plant configuration was in error and the corrective action was to reconfigure the plant.

Consequently, DDs that could have been dispositioned by other organizations competed with NE resources necessary to complete Unit 2 restart programs.

As a result the backlog of DDs increased.

3.

Corrective Ste s Which have been Taken and Results Achieved Site Director Standard Practice (SDSP) 9.1, "Processing Drawing Discrepancies,"

has been revised to establish the plant system engineer as the focal point for the dispositioning of drawing discrepancies.

This change reduces the administrative burden on NE and provides for immediate evaluation for detrimental effect on plant operation or nuclear safety.

SDSP 9.1 now uses the Potential Drawing Discrepancy (PDD) form (previously DD) to document and track apparent discrepancies between the plant configuration and the drawings which document the as-built plant.

It requires that the appropriate plant system engineer

Enclosure 2

Page 2 of 2

categorize the PDD based on potential impact on the safe and reliable operation of the plant.

This categorization establishes the priority for the subsequent resolution of the PDD.

PDDs affecting primary or critical drawings (drawings used by plant operations and technical support to determine system operation and function), or on secondary drawings which impact primary or critical drawings, are assigned the highest priority for resolution.

A PDD is resolved in one of three ways:

(1) the discrepancy is determined to be caused by an in-process work request (MR) or workplan and will be resolved during the normal work process, (2) the plant configuration is determined to be in error and a MR is generated to rework the plant to match the existing drawing or, (3)

NE work is determined to be required to resolve the discrepancy (the drawing error needs correcting, or design output is required to support the plant configuration) and a D-DCN is initiated.

The detailed handling of D-DCNs within NE is described in Browns Ferry Engineering Project (BFEP) Project Instruction (PI) 89-06, "Design Change Control".

Corrective Ste s Which will be Taken to Avoid Further Deviation Prior to Unit 2 restart the resolution of all PDDs written against or-impacting primary or critical drawings will be performed on a system return-to-service basis.

This provides better control of the cumulative impact of a large number of drawing changes on each system and reduces the number of drawing revisions required during the restart effort.

BFEP PI 88-07, "System Plant Acceptance Evaluation,"

requires that Unit 2 related DDs that affect primary or critical drawings and are within the boundary of the Design Baseline and Verification Program (DBVP) be closed prior to system return-to-service.

PI 88-07 also requires Unit 2 related D-DCNs/DDs that affect primary or critical drawings and are outside the DBVP boundary to have the affected primary or critical drawings updated and operability reviews performed prior to system return-to-service.

After system return-to-service, PDDs will be processed in a time frame which is commensurate with the PDD's impact on the plant.

PDDs will be categorized for processing as follows:

unit 2 related Category A PDDs (PDDs on primary or critical drawings which could create an adverse affect on plant operation, nuclear safety, industrial safety, or has the potential for contributing to operator error); unit 2 related Category B PDDs (PDDs on primary or critical drawings which do not appear to adversely affect plant operations, nuclear safety, industrial safety or have the potential for contributing to operator error); unit 2 related Category C PDDs (PDDs written against secondary drawings); all other Category C PDDs.

The processing of PDDs initiated after system return-to-service as discussed above will require revisions to the procedures BFN currently implements to process PDDs.

Date When Full Com liance Mill be Achieved BFN will implement procedures for processing PDDs according to the process described in this letter by September 15, 1990.

ENCLOSURE 3

Listing of Commitments 1.

Commitments Related to the Violation The physical replacement of the 3-inch weldolet will be completed by August 17, 1990.

2.

Commitments Related to the Deviation BFN's procedures for processing PDDs will be revised as appropriate to address the handling of PDD's after system return-to-service by September 15, 1990.