ML18033B663

Responds to Violations Noted in Insp Repts 50-259/90-40, 50-260/90-40 & 50-296/90-40.Corrective Actions:Complete Walkdown of Electrical Cable Stored Onsite Performed & Deficient Cables Segregated &/Or Removed

ML18033B663
Person / Time
Site:	Browns Ferry
Issue date:	03/22/1991
From:	Medford M TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9103270252
Download: ML18033B663 (22)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RZDS)

ACCESSION NBR:9103270252 DOC.DATE: 91/03/22 NOTARIZED: NO DOCKET FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tephessee 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) 1 I

SUBJECT:

Responds to notice of violation for Insp Repts ~50=259/90-"40, 3 D 50-260/90-40 & 50-296/90-40,re installation of improper materials & inadequate designs. Ensuring that personnel

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is properly trained & complete walkdown of electrical cable.

DISTRIBUTION CODE: IE01D COPIES RECEIVED LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response A

NOTES:1 Copy each to: B.Wilson,S. BLACK 05000259 1 Copy each to: S.Black,B.WILSON 05000260 1 Copy each to: S. Black,B.WILSON 05000296 L

RECIPIENT COPIES RECIPIENT COPIES ID HEBDON,F CODE/NAME LTTR ENCL' I D CODE/NAME LTTR ENCL 1 ROSS,T. 1 1 iZNTERNAL: ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1 AEOD/TPAB 1 1 DEDRO 1 1 NRR MORISSEAU,D 1 1 NRR SHANKMAN,S 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB 1 1 NRR/DREP/PEPB9D 1 1 NRR/DRIS/DIR 1 1 NRR/DST/DIR 8E2 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 OE DI~

R G~~-LE 1 1 OGC/HDS3 FILE 1

1 1

1 1 RGN2 01 1 1 R

EXTERNAL: EG&G/BRYCE,J.H. 1 1 NRC PDR 1 1 NSIC 1 1 NOTES: 5 5 D D

D NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 29 ENCL 29

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Tennessee Valley Autrtonty. 110t Market Streek Cnattanooga. Tennessee 37402 Mark O. Medford ViCe P~eSident. fduClear ASSuranCe. LiCenSing and FuelS MAR H 1991 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 BROGANS FERRY NUCLEAR PLANT (BFN) NRC INSPECTION REPORT 50-259, 260, 296/90-40 REPLY TO NOTICE OF VIOLATION (NOV)

This letter provides TVA's response to the NOV transmitted by letter from B, A. Wilson to 0. D. Kingsley, Jr. dated February 20, 1991. NRC cited TVA with a violation consisting, of two examples. The first example consists of three events in which improper materials were installed at BFN. The second example consists of three events in which inadequate designs were installed at BFN.

TVA agrees that the examples noted in the NOV violated regulatory requirements. Enclosure 1 to this letter is TVA's "Reply to the Notice of Violation" (10 CFR 2.201). Enclosure 2 provides a listing of commitments being made in this letter.

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

Very truly yours, TENNESSEE VALLEY AUTHORITY M. 0 ~ Medford Enc losures cc: See page 2 9lt.'t=;270- " 910-.22 FDr AxiCh: ~>5000=:-~

F'DR ggc/

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V.S. Nuclear Regulatory Commission MAR 22 $ 91 cc (Enclosures):

Ms. S. C. Black, Deputy Director Project Directorate 11-4 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 Hr. Thierry M, Ross, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Project Chief V.S. Nuclear Regulatory Commission Region II 101 Yiarietta Street, NW, Suite 2900 Atlanta, Georgia 30323

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Enclosure 1 Tennessee Valley Authority Browns Ferry Nuclear Plant (BFN)

Reply to Notice of Violation (NOV)

Inspection Report Number 50-259 260 296/90-40 I. INTRODUCTION In accordance with the Commission's Rules of Practice and Procedure, as described in the NRC staff's February 20, 1991 letter transmitting the subject NOV, TVA hereby replies to the NOV per the requirements of 10 CFR 2.201.

II. SlPPIARY OF POSITION The NOV identified as a concern the "failure to implement design control measures." TVA agrees that the examples noted violated regulatory requirements. More specifically, TVA concurs with the NRC staff assessment that the violations resulted from failure to follow the provisions of the BFN design control program.

TVA considers that the BFN design control program has been and continues to be sound. The deficiencies identified by TVA (and cited in the NOV) do not, in TVA's view, indicate a breakdown in design control. To the contrary, the process through which TVA identified these issues proves that the existing program does work. The checks and balances in the program allowe'd TVA to detect and correct deficiencies which had resulted from personnel error.

Enclosure 1 Page 2 III. REPLY TO THE NOTICE OF VIOLATION A. The NOV states:

"10 CFR 50 Appendix B, Criterion III, Design Control, requires that measures shall be established to assure the design basis are correctly translated into specifications, drawings, procedures, and instructions, and that measures shall be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structure, systems, and components.

Contrary to the above, activities involving design control were not being correctly implemented in accordance with requirements for the following two examples:

l. After problem reporting document BFP 900189P, that concerned the specification of cable design criteria, was issued on June 6, 1990, and the establishment of a qualified cable list per quality design change notice Q13819A on August 28, 1990, incorrect cables were installed in three applications. Approximately 3,470 feet of type PX unjacketed cable, instead of type PXJ jacketed cable, was installed for four design change notices. Design criteria BFN-50-758 did not allow use of Anaconda or THHN cables in other applications but these cables were installed or specified in design change notices.

2. During the performance of three post modification tests (PMTs) equipment failed to operate as designed because the drawings used in the design had not been updated with the latest design change or were incorrect.

During performance of PMT-BF-86-006, the RHR Inboard Injection Valve indicated both open and closed. at the local control stations because of a wiring error due to an incorrect drawing used in the modification workplan. A problem occurred with circuit breaker ope'ration after the slow bus transfer modification under DCN W14030 because the drawings used in the design change did not incorporate design information following an Appendix R modification. During PMT-BF-57.038 onl'y two of four logic relays operated because an incorrect drawing was used in the modification workplan.

This is a Severity Level IV Violation (Supplement I) applicable to all three units."

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Enclosure 1 Page 3 .

B. TVA's Res onse

l. Admission of Violation TVA agrees that the deficiencies violate regulatory requirements.

This example involved incorrect installation of three types of cables: Brand Rex, Anaconda, and THHN.

Brand Rex Cable: This event was the result of a personnel error. Unjacketed cable (PX) was issued and installed instead of the jacketed cable (PXJ) indicated in the design documentation. This event was self-identified by TVA during install'ation of the cable.

On November 9, 1990, a Condition Adverse to Quality Report (CAQR) was issued when a Quality Assurance inspector noted that a splice was being installed on unjacketed cable. The inspector was aware of the design criteria for splicing cable and this was not the installation he expected to see. investigation of the CAQR showed unjacketed cable was not qualified for installation and that the cable had been issued contrary to provisions in the BFN design control program.

Prior to this event, TVA had discovered that unqualified cable had been procured for installation at BFN. On June 6, 1990 a Problem Reporting Document (PRD) was issued to address this concern. Investigation of the event showed unjacketed cables had been procured which did not meet BFN design criteria. The resolution of this PRD was the issuance of a Quality Design Change Notice (QDCN). The QDCN provided a list of cables, by contract "

and work number, qualified for, installatiqn at BFN and was issued to maintenance, modifications, and procurement personnel. In addition, the QDCN was distributed by memorandum to ensure appropriate organizations were informed.

Contrary to the QDCN, TVA personnel issued unjacketed cable. The stores issue clerk, who 'is responsible for issuing materials from stores, was aware of the QDCN and the requirement to ensure cable issuance was -'n compliance. The individual did not review the'QDCN prior to issuing the cable; instead he operated from memory.

This was a personnel error for failure to follow provisions in the design control program when issuing cable. A contributing factor to this event was a weakness in the corrective action in response to the initial PRD issued June 6, 1990. TVA did not segregate or remove the unqualified cable from the warehouse.

Enclosure 1 Page 4 Anaconda Cable: This event was the result of personnel error. Anaconda cable was installed even though design documentation indicates that Anaconda cable is not to be issued for installation. This event was self-identified by TVA during a review of material requests'he review of material requests was performed after TVA identified the inappropriate use of Brand Rex type PX cable, previously discussed.

Design Criteria BFN-50-758, "Power, Control and Signal Cables of Use in Class I Structures," does not =allow cable with chlorinated polyethylene jacket (e.g. Anaconda cable) in Class I structures. Contrary to the design criteria, two Design Change Notices (DCN) were issued specifying the installation of Anaconda cables. In addition, the contract referenced in the DCNs was not on the list provided in the QDCN previously discussed.

This event resulted from personnel errors. The first personnel error was the listing of an unapproved contract on the DCNs. The second personnel error was the issuance of unqualified cable from the warehouse. A contributing factor to these personnel errors was a deficient corrective action response to the PRD issued June 6, 1990, as described above.

THHN Cable: This event was the result of personnel error. THHN cable was installed even though design documentation indicates that THHN cable is not to be issued for installation in the reactor building. This event was self-identified by TVA during a review of material requests. The review of material requests was performed after TVA identified the inappropriate used of Brand Rex type PX cable, previously discussed.

Design Criteria BFN-50-758 does not allow THHN cable to be installed in the reactor building. Contrary to the design criteria, a work order was issued specifying the installation of THHN cable for a non-safety related cable application (drywell lighting). In addition, the contract referenced in the work order was not on the list provided in the QDCN previously discussed.

0 Enclosure 1 Page 5 This event resulted from personnel errors. The first personnel error was the listing of an unapproved contract on the work order. The second personnel error was the issuance of unqualified cable from the warehouse. A contributing factor to these personnel errors was a deficient corrective action in response to the PRD issued June 6, 1990, as described above.

This example involved the improper installation of three modifications: injection valves, shutdown boards, and diesel

'generator relays.

In 'ection Valves: This event was the result of a personnel error. The individual preparing the workplan for this 'modification did not include the latest revision of a design drawing. This event was self-identified by TVA during the performance of the PMT when an inboard injection valve indicated both open and 'closed at the local control station.

In this event, a design change was issued to replace an existing cable in the plant. Since the cable terminations were not being revised, the cable termination drawing was not required to be included in the design. However, Site Director Standard Practice (SDSP) 8.4, "Modification Workplans," states: "If the design change provided no Associated Drawing List, use the latest revision drawing available from Document Controls and Records Management." Contrary to SDSP 8.4, the workplan which implemented this design change did not incorporate the latest revision of cable termination the drawing due to a personnel error.

2. Shutdown Boards: This event was the result of a personnel error. The individual preparing a design change did not include the latest rev'sion of a design drawing. This event was self-identified by TVA during the performance of a 'PMT, when an alternate power feeder breaker tripped and would not close.

In this event a design change was issued which required the four alternate feeder breakers, associated with the Unit 1 and Unit 2 shutdown boards, to trip during the presence of an accident signal.

Enclosure 1 Page 6 BFN Project Instruction (PI) 89-06, "Design Output,"

states "Design documents used as a basis for development of a DCN shall be the latest issue of the Nuclear Engineering (NE) approved documents of record,..."

Contrary to PI 89-06 the approved design change did not include the latest revision of a required drawing due to a personnel error.

3. Diesel Generator Rela s. This event was the result of a personnel error. The individual that prepared a data sheet for landing leads failed to implement the approved design change. This event was self-identified by TVA during the performance of a PMT when only two-out of four diesel generator voltage available (DGVA) relays operated.

In this event a design change was issued to modify the DGVA relays. The design change provided a markup of a controlled drawing to illustrate the correct termination locations for a cable. During preparation of a workplan, the data sheet for landing leads failed to correctly implement the markup of the drawing due to a personnel error. This personnel error resulted in the electrical leads being terminated at the wrong location.

2. Corrective Ste s Taken and Results Achieved The common element of these events is personnel error.

Accordingly, TVA continues to emphasize to its employees at BFN the importance of strict procedural adherence. In addition to the specific corrective steps identified below for each example, TVA has stressed that each individual is responsible for ensuring accuracy and quality in the work they perform. Notwithstanding the messages that plant management has periodically delivered to site personnel regarding procedure adherence, in his March 15, 1991 Site Director's Message, the BFN Site Director reiterated the need to adhere strictly to procedures. Furthermore, he cautioned that hasty or inadequate reviews destroy the credibility of the work.

In addition to the Site Director's message, discussed above, TVA issued a memorandum to all NE personnel .on January 25, 1991.

This memorandum stressed the importance of ensuring quality work in addition to ensuring compliance with procedures. Furthermore, this memorandum stressed the importance of each individual's role in the restart of Unit 2 and in the production of high quality products by NE.

I Enclosure 1 Page 7 The following corrective steps apply to all three events described in this example: Brand Rex, Anaconda, and THHN cables. These steps take the actions necessary to ensure personnel are properly trained, unqualified cable has been evaluated and cables installed in the plant are acceptable.

First, SDSP-16.16, Material Issuance and Return, has been revised to address the concerns described in the violation.

Training of power stores personnel on this revision has been completed. Also, additional training was provided to personnel in the procurement engineering and electrical design groups on design criteria BFN-50-758.

Second, a complete walkdown of electrical cable stored on site has been performed. The results of this walkdown were evaluated to ensure the cables are in compliance with the requirements of BFN-50-758. Cable found not to be in compliance with the requirements of BFN-50-758 has been segregated and/or removed from site.

Finally, a review of all cables issued for installation in the plant after August 1, 1987, has been completed. This review ensured cable installations in the plant meet the requirements of BFN-50-758. Cables installed in the plant which do not meet the requirements of BFN-50-758 will be evaluated and/or replaced as necessary prior to the restart of each unit at BFN.

b. ~Exam le 2:

1. In 'ection Valves: For this'vent, the workplan was revised to include the latest revision, of the required drawing. The affected cable associated with the Residual Heat Removal system inboard injection valve was reterminated and the PMT was completed successfully.

2. Shutdown Boards: For this event, the design change was reissued to include the latest revision of the required drawing. The plant modification was performed to implement the required revision for the alternate power feed breaker modifications and, the PMT was successfully completed. In addition, personnel corrective actions were taken in accordance with TVA policies and procedures.

3. Diesel Generator Rela s: For this event the landed lead data sheet was revised to accurately implement the design change. The cable was reterminated for the DGVA relays, based on the revised data sheet and the PMT was successfully completed.

Enclosure 1 Page 8

3. Corrective Ste s Which Will be Taken

a. ~Exam le 1:

Cables installed in the plant after August 1, 1987, which do not meet the requirements of BFN-50-758, will be evaluated and/or replaced prior to the restart of each uni.t.

b. ~Exam le 2:

No further corrective actions are required.

4.'ate When Full Com liance Will Be Achieved

'Programmatically, TVA is in full compliance with the requirements of 10 CFR 50, Appendix B, Criterion III, Design Control.

Regarding specific cable evaluations and/or replacements, TVA will be in full compliance prior to the restart of each unit at BFN.

IV. CONCLUSION In conclusion, TVA considers that the examples noted in the NOV resulted from personnel error. That is, individuals involved failed to follow the provisions of the design control program. Accordingly, TVA considers that these events are not indicative of a programmatic breakdown. TVA has taken steps to correct the specifics of each example and has provided additional training where necessary to minimize the probability of recurrence of these types of events. Furthermore, TVA continues to stress to personnel at BFN the need for strict procedural adherence.

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Enclosure 2 Listin of Commitments

1. Cables installed in the plant after August 1, 1987, which do not meet the requirements of TVA Design Criteria BFN-50-758, "Power, Control and Signal

, Cables of Use in Class I Structures," will be evaluated and/or replaced as necessary prior to the restart of each unit.

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