ML18033B732
| ML18033B732 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/21/1991 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9106260164 | |
| Download: ML18033B732 (17) | |
See also: IR 05000259/1991010
Text
D SUBTECT: Responds to NRC 910510 ltr re violations
noted in Insp Repts<50-259/91-10
>50-260/91-10
&50-296/9-10.Corrective
actions: mod closure process for vacuum breakers revised&new nuclear power std on equipment clearances
issued.DISTRIBUTION
CODE: IEOID COPIES RECEIVED:LTR
J ENCL Q SIZE:/0 TITLE: General (50 Dkt)-Insp Rept/Notice
of Violation Response A 05000259 D 05000260 05000296 NOTES:1 Copy each to: B.Wilson,S.
BLACK 1 Copy each to: S.Black,B.WILSON
1 Copy each to: S.Black,B.WILSON
REGULATORY
INFORMATION
DISTRIBUTION
SYSTEM (RIDS)ESSION NBR:9106260164
DOC.DATE: 91/06/21 NOTARIZED:
NO DOCKET g CIL:50-259
Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 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)RECIPIENT I D CODE/NAME HEBDON,F WILLIAMS,J.
RNAL: ACRS AEOD/DEIIB
DEDRO NRR SHANKMAN,S
NRR/DOEA/OEAB
NRR/DRIS/DIR
NRR/PMAS/ILRB12
0 EG F L 02 EXTERNAL: EG&G/BRYCE, J.H.NSIC NOTES: COPIES LTTR ENCL 1 1 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 5 5 RECIPIENT ID CODE/NAME ROSS,T.AEOD AEOD/TPAB NRR MORISSEAU,D
NRR/DLPQ/LPEB10
NRR/DREP/PEPB9H
NRR/DST/DIR
8E2 NUDOCS-ABSTRACT
OGC/HDS3 RGN2 FILE 01 NRC PDR.COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 D NOTE TO ALL"RIDS" RECIPIENTS:
D D PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION
LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 30 ENCL 30
TenneSSee Valley AuthOrity.
t t01 Market Street.ChattanOOga, TenneSSee 37402 Mark O.Medford Vice P~esident.
Nuclear Assurance, Licensing and Fuels JUN 211991 U.S.Nuclear Regulatory
Commission
ATTN: Document Control Desk Washington, D.C.20555 Gentlemen:
In the Matter of Tennessee Valley Authority Docket Nos.50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN)-NRC INSPECTION
REPORT 50-259, 260, 296/91-10-REPLY TO NOTICE OF VIOLATION (NOV)This letter provides TVA's reply to the NOV transmitted
by letter from B.A.Wilson to Dan A.Nauman, dated May 10, 1991.NRC cited TVA with two violations.
The first violation contains two examples for failure to implement test control measures for returning components
to service, The second violation addresses two examples of failure to comply with Technical Specification
requirements
for not obtaining required compensatory
samples.TVA agrees that the violations
noted in the NOV violated regulatory
requirements.
Enclosure 1 to this letter is TVA's"Reply to the Notice of Violation" in accordance
with 10 CFR 2.201.A listing of commitments
made in this letter is provided in Enclosure 2.As agreed with your Staff, the submittal date for this reply was extended to June 24, 1991.9106260164
910621 PDR ADDCK 0 0t.t025'e 9 PDFi
U.S.Nuclear Regulatory
Commission
JUN 21 1991 If you have any questions regarding this response, please telephone Patrick P.Carier at (205)729-3570.Very truly yours, TENNESSEE VALLEY AUTHORITY Mark O.Medford Enclosures
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
Mr.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 U.S.Nuclear Regulatory
Commission
Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
,
Enclosure 1 Tennessee Valley Authority (TVA)Browns Ferry Nuclear Plant (BFN)Reply to Notice of Violation (NOV)Inspection
Report Number 50-259 260 296/91-10 NRC cites TVA with two violations.
The first violation involved two examples for failure to implement testing program requirements.
TVA agrees that a violation occurred in both examples.In example 1, adequate post modification
testing (PMT)requirements
were not performed due to a lack of administrative
control.This resulted in a field change request (FCR)not being reviewed prior to testing.In example 2, the residual heat removal service water (RHRSW)pump was not caution tagged due to personnel error.The second violation was for failure to maintain Technical Specification (TS)requirements
for compensatory
sampling.TVA agrees that a violation of regulatory
requirements
on compensatory
sampling occurred.The violation was due to poor work practices which resulted in two compensatory
activities
being signed off as complete when they were not performed.
VIOLATION A During the Nuclear Regulatory
Commission (NRC)inspection
conducted on March 16-April 19, 1991, a violation of NRC requirements
was identified.
The violation involved examples of failure to implement testing program requirements.
In accordance
with the'General Statement of Policy and Procedure for NRC Enforcement
Actions,'0
CFR Part 2, Appendix C (1990), the violation is listed below: "10 CFR50 Appendix B, Criterion XI, Test Control, requires that a test program shall be established
to assure that all testing required to demonstrate
that structures, systems, and components
will perform satisfactorily
in service is identified
and performed in accordance
with written test procedures
which incorporate
the requirements
and acceptance
limits contained in applicable
design documents.
Test results shall be documented
and evaluated to assure that test requirements
have been satisfied.
Page 2 of 7 Contrary to the above, activities
involving test control were not correctly implemented
in accordance
with requirements
for the following examples: Adequate post modification
testing (PNT)requirements
were not stipulated
following completion
of design change P3051.The reactor building to torus vacuum breakers opened unexpectedly
when torus pressure was greater than reactor building pressure during the integrated
leak rate test on March 18, 1991.The vacuum breakers are designed to vent air from the reactor building to the torus when reactor building pressure exceeds torus pressure by 0.5 psig.2.During the return to service activities
for the A3 residual heat removal service water pump, PMT was not completed.
The pump was not caution tagged as required by procedure SDSP 14.9, for components
awaiting PNT.The pump failed to start on October 4, 1990, when aligned to start for testing the 3D diesel generator.
The cause was later determined
to be a wiring error during implementation
of DCN W4515A.The same pump failed to autostart on September 27, 1990, during diesel generator testing and the cause had not been determined
as of October 4, 1990.This is a Severity Level IV Violation (Supplement
I)applicable
to all three uni ts~VIOLATION B"TS Section 3.2.D requires that radioactive
liquid effluent monitoring
instrumentation
listed in Table 3.2.D to be operable when effluent releases are in progress via the instrument
pathway.Table 3.2.D includes Raw Cooling Water (RCW)monitor 2-RN-90-132.
TS 3.2.D also requires that grab samples be collected and analyzed at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> when the RCW monitor is inoperable
and effluent releases are continued.
TS Section 3.2.K requires the radioactive
gaseous effluent monitoring
instruments
listed in Table 3.2.K to be operable.Table 3.2.K includes Reactor/Turbine
Building Ventilation
monitors 1-RM-90-250, 2-RM-90-250, and 3-RM-90-250
and Radwaste Building Ventilation
monitor 0-RN-90-252.
TS 3.2.K also requires that actions be taken whenever the instruments
are declared inoperable
and effluent releases are being conducted through an affected pathway.The required actions include a flow rate estimate at least once every four hours.Contrary to the above, on March 1, 1991, the licensee determined
that surveillance
instruction
data was not valid for the following two examples: 1.Flow rate estimates taken on December 5, 1990, at 4:00 a.m., for inoperable
monitors 1-RN-90-250, 2-RN-90-250, 3-RN-90-250, and O-RN-90-252.
Page 3 of 7 2.A compensatory
grab sample taken on December 11, 1990, at 10:03 a.m., for inoperable
RCW monitor 2-RM-90-132.
This is a Severity Level IV Violation (Supplement
I)applicable
to all three Units." TVA'S REPLY TO VIOLATION A EXAMPLE 1 l.Admission of Violation TVA agrees that a violation occurred.2.Reason for Violation This violation was caused by a lack of administrative
control.An adequate PMT was not performed because a FCR was not reviewed for impact on the PMT.The FCR modified pressure differential
transmitters (PDTs)for the vacuum breakers.At the time of this modification
there were no procedural
requirements
for the FCR to be reviewed for PMT requirements.
Engineering
Change Notice P3051 installed PDTs for the vacuum breaker valves (2-FCV-64-20
and 21).The modification
of the sensing lines to the PDTs was implemented
by WP 2036-84.The high and low side of the PDTs were connected to the process sensing lines in January 1987, and a walkdown of the PDTs was completed in July 1987.This walkdown was required to ensure that the instrument
lines were not reversed.PMT of the PDTs was started in August 1987 prior to the completion
of WP 2036-84.However, before the PMT of the PDTs was completed, WP 2036-84 was revised by a FCR to incorporate
vendor recommendations
on the PDTs.This involved rotating and reinstalling
the PDTs with the high side vent located on the top of the transmitters.
After the transmitters
were rotated, the sensing lines were incorrectly
attached to the PDTs.The revised WP was not reviewed again to ensure adequate PMT was performed on the PDTs.Other factors contributed
to the incorrect installation
of the sensing lines and the WP not being reviewed.These factors included the extended duration of the modification
and testing, and several changes in test directors and modifications
personnel resulting in the loss of continuity.
Page 4 of 7 Corrective
Ste s Taken and Results Achieved In this event, the FCR incorporating
the vendor recommendations
was not reviewed for impact on PMT.To address this weakness, the procedure governing modification
closure, Site Director's
Standard Practice (SDSP)12.4, now requires relevant FCRs, final design change notices (F-DCNs)and other safety design or testing changes (e.g., 10 CFR 50.59 review revisions)
be formally reviewed against the final as-built condition and final design requirements.
SDSP 12.4 also requires copies of F-DCNs to be distributed
to plant organizations
to inform them of minor changes to a modification
during implementation.
Additionally, this SDSP includes piping reroute modifications
as an item to be considered
by the system engineer during the field survey conducted just prior to plant acceptance
of a modification.
In addition, plant procedures
have been revised as part of the procedure upgrade program since the modification
of the PDTs.The PMT program now has its own governing document, SDSP-17.2.
This SDSP requires that each PMT instruction
have a prerequisite
addressing
review of the modification
installation
status.This delineates
review of any field change completion
status, and the impact of incomplete
or partially complete modification
status on initial testing.Also, configuration
control is maintained
in the test record drawings and these test record drawings require concurrence
signatures
by the implementing
organization, a Nuclear Engineering
representative, and the test director.This combined drawing review prior to the beginning of the test will detect any unincorporated
field changes affecting the test performance.
Finally, since the modification
of the PDTs of the vacuum breakers, the modification
closure process has been refined.This closure process now includes a revised modification
work completion
statement (SDSP-133)
form that lists the affected drawings and field changes.System engineers are required to review the SDSP-133 forms and are responsible
for system testing.This minimizes breaks in continuity.
Corrective
Ste s Which Will Be Taken No further corrective
steps are required.Date When Full Com liance Will Be Achieved TVA has achieved full compliance.
Page 5 of 7 EXANPLE 2 , Admission of Violation TVA agrees that a violation occurred.2.Reason for Violation This violation was caused by personnel error.In this event, a caution tag was not placed on the control switch for the A3 RHRSW pump as required by SDSP 14.9, Equipment Clearance Procedure, for components
awaiting PMT.Additionally, an inadequate
review of open corrective
action documents (i.e.test deficiency
and work order)from the diesel generator testing on September 27, 1990, permitted the incorrect assignment
of the A3 RHRSW pump to autostart on October 4, 1990.This inadequate
review is due to failure to adhere to Plant Managers Instruction (PMI)17.1, Conduct of Testing.Both conditions
were the result of personnel errors and indicate a lack of awareness of procedural
requirements.
A contributing
factor to this event was the inconsistent
personnel interpretation
of the word"immediately" as used in SDSP-14.9.
SDSP-14.9 states,"If maintenance
is performed...but the specified Post Maintenance
Testing cannot be completed immediately
following the maintenance, a caution order will be issued..." Interviews
with plant personnel indicated that the term"immediately" was interpreted
to mean a time frame that could extend up to several hours.3.Corrective
Ste s Taken and Results Achieved The October 4, 1990 event has been investigated, and the incident investigation (II)report of this event was reviewed with operations
personnel to emphasize the importance
of attention to detail and adherence to plant procedures.
Additionally, TVA has performed a Human Performance
Enhancement
System (HPES)evaluation
on the personnel involved, and the results of this HPES have been incorporated
as part of the II to prevent recurrence.
Subsequent
to this event, an additional
II (II-B-91-074)
was performed to review caution orders issued for equipment awaiting PMT.This investigation
revealed that prior to October 4, 1990, very few caution orders were written that denoted a PMT which had not been completed.
However, in the last quarter of 1990 and in the first quarter of 1991, the number of PMT-related
caution orders has substantially
increased.
TVA considers the increased number of PMT-related
caution orders can be credited to the current level of awareness resulting from review of the October 4, 1990 event.
Page 6 of 7 To prevent recurrences
on PMT-related
caution orders, the operator requalification
training lesson plan for the equipment clearance procedure has been revised to include the requirement
for caution orders to be placed for equipment awaiting PMT.Additionally, a computerized
clearance tracking system has been implemented
at BFN.This system will automatically
generate the caution tags which are required after maintenance.
4.Corrective
Ste s Which Will Be Taken Licensed and non-licensed
operators will review the II (II-B-91-074)
during their required reading, and this investigation
will be discussed with licensed operators by the Operations
Superintendent.
During this discussion
the Operations
Superintendent
will counsel each group on adherence to procedures, and reinforce Operations'olicies
concerning
equipment awaiting PMT.On April 4, 1991, a new TVA Nuclear Power Standard on equipment clearances
was issued.The standard has been reviewed by Operations
and defines the process by which caution tags are placed on equipment following maintenance.
The standard will be fully implemented
at BFN as a Site Standard Practice (SSP).This SSP will use the Technical Specification (TS)definition
of immediate, which means"the required action will be initiated as soon as practicable
considering
the safe operation of the unit and the importance
of the required action." Also, steps will be included in the practice that require equipment subject to automatic starts to have the caution order place the electrical
power sources in the non-operating
position.5.Date When Full Com liance Will Be Achieved Full compliance
will be achieved by September 15, 1991.TVA'S REPLY TO VIOLATION B EXAMPLES 1 AND 2 1.Admission of Violation TVA agrees that a violation occurred.2.Reason for the Violation This violation was caused by poor work practices.
The poor work practices resulted in two compensatory
activities
being signed off as complete when they were, in fact, not performed.
Page 7 of 7 As a result of a previous occurrence
involving missed compensatory
samples TVA reviewed Reactor Building entry data, refuel floor entry logs, Surveillance
Instruction (SI)data sheets, and conducted personnel interviews.
Based on the results of this review, TVA discovered
that Radiochemical
Laboratory
Analysts (RLAs)did not always sign off SI steps as they were performed, RLAs sometimes signed off steps that other RLAs performed, RLAs on occasion contacted other plant personnel for compensatory
flow readings, and the Chemistry Shift Supervisors (CSSs)did not always ensure SIs were completed when performed.
3.Corrective
Ste s Taken and Results Achieved Chemistry management
administered
personnel corrective
action to the employees involved in accordance
with TVA policy.In addition, Chemistry personnel were issued a memorandum
providing retraining
on the significance
of signatures/initials
in procedures.
This memorandum
clearly outlined management's
expectations
and the consequences
of non-compliance.
A similar site-wide memorandum
was issued discussing
the same subject.These actions should heighten the awareness level of chemistry personnel to the significance
of signatures.
For recurrence
control, chemistry management
is requiring the CSS to take a more active role in monitoring
shift activities.
Sign-offs for the CSS have been added to all the chemistry compensatory
SIs so that the CSS verifies completion
of each individual
compensatory
measure.Additionally, Chemistry management
conducted a two-week assessment
of laboratory
practices;
their observations
concluded that programmatic
deficiencies
did not exist.Finally, this event was referred to TVA's Office of Inspector General (OIG).The OIG confirmed that the incident was adequately
addressed and considers this matter closed.4.Corrective
Ste s Which Mill be Taken No further corrective
steps are required.5.Date When Full Com liance Will be Achieved TVA has achieved full compliance.
Enclosure 2 Listin of Commitments
for Violation A l.Operators will review Incident Investigation
II-B-91-074, and this investigation
will be discussed with licensed operators by the Operations
Superintendent.
The Operations
Superintendent
will counsel each group on adherence to procedures, and reinforce Operation's
policies concerning
equipment'awaiting PNT.This review will be completed by September 15, 1991.2.TVA's Nuclear Power Standard on equipment clearances
will be fully implemented
at Browns Ferry as a Site Standard Practice (SSP).This SSP.will use the technical specification
definition
of immediate and will include steps that require equipment subject to automatic starts to have the caution order place the electrical
power sources in the non-operating
position.This action will be completed by September 15, 1991.
h