ML20092D209

Responds to NRC 840314 Ltr Re Violations Noted in IE Insp Repts 50-259/83-60,50-260/83-60 & 50-296/83-60.Corrective Actions:Clearance Procedure Revised.Response to Violation 2 Will Be Submitted by 840514

ML20092D209
Person / Time
Site:	Browns Ferry
Issue date:	04/16/1984
From:	Kammer D TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20092D178	List: ML20092D189 ML20092D209
References
NUDOCS 8406210517
Download: ML20092D209 (6)

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. y TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374ot 400 Chestnut Street Tower II 23 Pl2 : 2 5 April 16, 1984 U.S. Nuclear Regulatory Commission Region II ATTN: James P. O'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Enclosed is our response to R. C. Lewis' March 14, 1984, letter to H. G. Parris transmitting Inspection Report Nos. 50-259/83-60,

-260/83-60, -296/83-60 regarding activities at our Browns Ferry Nuclear Plant which appeared to have been in violation of NRC regulations. On April 13, 1984, Mike Hellums of my staff and Ross Butcher of your staff discussed a one-day extension to April 16, 1984 for submitting our response, except for Violation 2, which will be submitted on May 14, 1984. We have enclosed our response to the Notice of Violation, minus the response to Violation 2 which will be submitted on May 14. If you have any questions, please call Jim Domer at FTS 858-2725. ,

I To the best of my knowledge, I declare the statements contained herein are complete and true.

! Very truly yours, TENNESSEE VALLEY AUTFORITY 95( W D. S. Kammer J

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Nuclear Engineer Enclosure i

0 Db 0 h9 PDR An Equal Opportunity Employer

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• RESPONSE - NRC INSPECTION REPORT NOS.

50-259/83-60, 50-260/83-60, AND 50-296/83-b0 RICHARD C. LEWIS'S LETTER TO H. G. PAHRIS DATED HARCH 14, 1984 Item 1 (259/83-60-05) 10 CFR 50, Appendix B, Criterion V requires that activities affecting quality shall bo proscribed by documented instructions and procedures. The plant clearance procedure (Standard Practico 14.25) for tagout of equipment specifies requirements to be followed in placing equipment in and out of service.

Contrary to the abovo, the requirements of DF 14.25 woro not mot in that tagout clearance procedures were not followed for placing the root valvo for pressure transmitter 64-137 and 64-136 back in servico on October 18, 1983, on clearance 83-1232. The operator assigned to return the system to servico did not place the valvo in the open position and did not remove the tag attached to the valvo. This resulted in tho drywell to torus instrumentation being out of servico during power operation. Additionally, the valvo was not verified open during pre-startup valvo lineups. The valve was found mispositioned 5 days aftor unit startup during a routino surveillance.

This is a Severity Level IV Violation (Supplement I) applicable to unit 1.

1. Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

2. Reasons for the Violation if Admitted This was personnel error in that the operator fallod to return the valve which was identified on the clearanco shoot to the required position as the system was returned to service.

3. Corrective Steps Which Have Boen Taken and the Results Achieved Disciplinary action was taken against the operator involved and tho error has boon discussed with operations personnel both on shift and in training.

4. Correctivo Stops Which Will Do Taken To Avoid Further Viointions The clearanco proceduro (Standard Practico 14.25) has boon revised to include two-party verification on return to service of safoty or safety-related systems when a clearanco is rolossed to provont further problems.

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5. Dato When full comptinnen W111 la Achtoved full complianco was acnieved february 3, 1984, when the prococure revision was issued.

Item 3 Technical Spectrication 6.3.A.1 requir1s that dotalled written proceduros bo prepared, approved and adhered to related to plant startup and operation.

Contrary to the above, the requiremont was not mot in that A. Operating Instruction 64 (Primary Containment System Startup Checklists and Valvo Lincups) was found to be inadoquato sinco it doos not includo the instrument isolation valvos for the drywell and torus pressure consing lines connected to pressure transmittors PDT 64-137 and FDr 64-138. failure to have one of thoso valvos in service resulted in both of the dry 1'. to torus differential pressure instruments boing out of servico durin6 power operation.

B. Gonoral Operating Instruction 100-1 (Pro-startup Chock 11sts) required that all chart recorders on panol 9-3 bo placed in service prior to startup of Unit 1 on December 4 1983 The recorder's torus pressure indicating otrcuit romained doonorgized until January 10, 1984.

This is a Severity Lovel IV Violation (Supplomont I) applicable to all units.

Item 3A (259, 260, 296/63-60-03) 3

1. Adminston or Dontal of the Allecod Violation TVA admits the violation occurred as stated.

2. llennonn for the Violatton if Admittnd The valvo was not shown on primary flow drawings or on instrument panol drawings which are used to develop checklists. The torus contractor provided original drawings of torus ponotrations. l l

3 Corrootivo Star: Whtoh ihvo Iwnn Taken_and the Itonultn Ach(avod i i

An-constructed status of all torus instrument linos has boon veriflod by walkdown. In addition, an indopondent walkdown to verify reactor protootion system instrumontation linos has boon performed.

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4. Corrective Stops Whtoh Will be Taken To Avoid Further Violations The valves identified by the status verification walkdowns have been added to the necessary instrument oneckliata. Any other drawing discrepancies found during those reviews are being corrected.

5. Date When fuit Comottance W111 De Achieved full compliance was achieved on february 23, 1984, when the checklists were revised to include taolation valves for PDT 64-137 and -138.

Item 3D (259/63-60-03)

1. Adminston or Dental of the Alleged Violation TVA admits the violation occurred as stated.

2. Dennons for the Vlointion if Admitted The recorder was found to be turned off. It was expected that the recorder was defective, but when tue recorder was turned on, it operated properly. The procedure did not identify an action to take in tne event of an inoperable recorder.

J. Corrective Stars Whtoh llave Dean Taken and the Resulta Achieved The instrument aeotion made additional checks of all control room recorders to ensure needed repairs were made for four weeks. Also, an information nottoe was sent to all operators on January 13, 1904, to ensure profer maintenance and operation of recorders.

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Cnrrective Stars Which Will be Taken To Avoid further Violations A revision will be made to the instruction to notify the abitt engineer when inoperable recorders are identified in the prestartup checks for determination of system operability.

5. Date When full coucliane. W111 he Achiaved full compliance will be achieved by June 30, 1984 1

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4 Item 4 (2$9/63-60-02)

Technical Opeoitication 3 6.8 3 requires that at steaming ratos greator than 100,000 lb/hr., the reactor water quality chloride maximum limit of O.5 ppm ahall not be exceeded. Exooecing thin limit shall be cause for placing the reactor in the cold shutdown condition.

l l~ Contrary to the above, this requirement was not met in that reactor water quality chlorido exceeded 0 5 ppm from 0370 a.m. to 11:40 a.m. on Locomber 31, 1903, without any action being taken to commence an orderly shutdown. An orderly shutdown was initiated at 12:20 p.m.,

December 31, 1983, due to water quality being out of speoirication and

! possible resin intrusion. Operational supervisory personnel were not made aware of the chloride out of specification conditio : until 11:05 a.m.,

December 31, 1983 An orderly shutdown was terminated at 2:35 p.m. after chlorido concantration was confirmed to be within specification and the suapooted source isolated.

This la a Severity 1.evel IV Violation (Capplement I) applicable to Unit 1.

1. Adminaten or Dental of the Allagad Violation TVA admits the violation occurred as stated.

2. Pa4aon9 for the Vio14ttan if_AdmittaA A miscommunication between chemistry laboratory personnel and operationa peraonnel regarding unit status resultad in confualon which delayed the shutdown initiation. failure of the chemistry laboratory analyst to report the out of apoctrication chloride condition to the shift ergineer enhanced the problem.

3. Correctiva # tan Whiah lleva baan Teken aid the Panulta Aehlavad A critique of the event was held with all chemistry laboratory personnel. The following points were discussed: A onronology of the event, the need to communicate out of apecification conditions to the shift engineer, the need to consult technical spectrications and surveillance instructions for actions required in renponae to an out of-apecification condition, and the need to develop a better method to define unit atatua suon that technical specification requirements are correspondingly clarified. A method for defining unit status by chemintry laboratory personnet has been developed.

4 Corraaliva otyLWhlah Will ba Taken To Avoid further Violations l No further corrective action la required.

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5. Date When Full Compliance Will be Achieved 4

Full compliance was achieved January 16, 1984.

Item 5 (259, 260, 296/83-60-04) 10 CFR 50, Appendix B, Criterion V requires that activities affcoting quality shall be prescribed by documented instructions,' procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, this requirement was not met in that Mechanical Instruments and Controls drawing 47W600-133 incorrectly showed the instrument lines between the drywell and torus to transmitters PT-64-135 and PDT-64-137 These lines were found reversed from the drawing indication during a resident inspector walkdown of the system. System operation was not impaired as the installation was correct with only the drawing in error.

This is a Severity Level V Violation (Supplement I) applicable to all units.

1. Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

2. Reasons for the Violation if Admitted The original drawing was in error. The drawing error had been independently identified by TVA and proper corrective action had been undertaken.

3 Corrective Steps Which Have Taken and the Results Achieved A category "D" field change request (number 3290).was written and engineering change notice (ECN) P5063.was written by the Division of Engineering Design.

4. Corrective Steps Which Will Be Taken To Avoid Further Violations Drawing 47W600-133 will be revised by means of a workplan-when ECN P5063 has been received at the plant.

5. Date When Full Compliance Will Be Achieved full compliance will be achieved by November 1, 1984.

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