ML18036A845

Provides Response to 920803 Ltr Re Violations Noted in Insps Repts 50-259/92-24,05-260/92-24 & 50-296/92-24.Corrective Actions:Mod Criteria for Corrosion Monitors Dcn & Valve Data Sheet Containing Erroneous Info Corrected

ML18036A845
Person / Time
Site:	Browns Ferry
Issue date:	08/31/1992
From:	Zeringue O TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9209040100
Download: ML18036A845 (10)

See also: IR 05000259/1992024

Text

i.A V~@%0 I~i W~vl'i'~.I ACCELERATED

DISTRIBUTION

DEMONSTRATION

SYSTEM REGULATORY

INFORMATION

DISTRIBUTION

SYSTEN (RIDS)CESSION.NBR: 9209040100

DOC.DATE: 92/08/31 NOTARIZED:

NO DOCKET 0 CIL: 50-259'roens

Ferry Nuclear Poeer Station, Unit 1, Tennessee 05000259 , 50-260 Broens FerrM Nuclear Power Stationi Unit 2i Tennessee 05000260 50-296 Broens Ferry Nuclear Power Stationi Unit 3i Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION

ZERINGUEI O.J.Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION

R Document Control Branch (Document Control Desk)SUBJECT: Provides respo'nse to 920803 ltr re violations

noted fn Insps Rep ts 50-259/92-24'5-260/92-24

5 50-296/'P2-24.

Corr ec tive actions:mod

criteria for corrosion monitors DCN h valve data sheet conta'ining

erroneous info corrected.

I DISTRIBUTION

CODE: IEDID COPIES RECEIVED: LTR ENCL+SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response NOTES: A REC IP IENT ID CODE/NAME HEBDONI F MILLIAMSI J.INTERNAL: ACRB t AEOD/DEIB*EOD/TTC NRR MORISSEAUI

D NRR/DLPG/LPEB10

NRR/DREP/PEPBVH

NUDOCB-ABSTRACT

OGC/HDS3 RGN2 F ILE 01 EXTERNAL: EGZcG/BRYCEI

J.H.NSIC COPIES LTTR ENCL 1 1 1 1 2 2 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 REC IP IENT ID CODE/NAME ROSSI T.AEOD AEOD/DSP/TPAB

DEDRO NRR/DLPQ/LHFBPT

NRR/DOEA/OEAB

NRR/PMAS/ILRB12.E REG FILE 02 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 NOTE TO ALL"RIDS RECIPIENTS

PLEASE HELI" US TO R" DUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK.ROOM pi-".7 (EXT.504-2065)TO ELIMIINATE

YOUR NAME FROM DISTRIBUTION

LiSTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

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0 Tennessee Valley Authority, Post Office Box 2000, Decatur,'Alabama

35609 O.J.'Ike'eringue

Vice President, Browns Ferry Operatfons

AUG 3i>99Z 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, 296/92-24-REPLY TO A NOTICE OF VIOLATION (NOV)This letter provides TVA's reply to the NOV transmitted

by letter from B.A.Wilson'ated

August 3, 1992.In this letter, NRC cited TVA with a violation for failure to use the correct hydrostatic

test pressures to adequately

test component welds of a safety system.TVA shares the Staff's concern that a system was tested improperly.

However, TVA notes that although one loop of the Residual Heat Removal system was conservatively

declared inoperable, the system was subse'quently

confirmed capable of performing

its design function.Furthermore, TVA is encouraged

that this condition was discovered

because plant personnel had a questioning

attitude during the performance

of their routine activities.

In this case, a supervisor

had identifie'd

a problem during the processing

of a routine workplan change;In response to that discovery, an engineer initiated a review of other workplans for similar errors.It was during that expanded review that the condition cited in the violation was identified.

/1 n P1~pp83f o c()~PPPa5~.

6

U.S.Nuclear Regulatory

Commission

NB 31 1992 TVA's"Reply to the Notice of Violation" (10 CFR 2.201)is contained in the enclosure to this letter.If you have any questions regarding this response, please telephone Raul R.Baron at (205)729-7566.Sincerely, J.Zering e Enclosure cc (Enclosure):

.NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611 Mr.Thierry M.Ross, Project Manager U.S.Nuclear Regulatory

Commission

One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852'r.B.A.Wilson, Project Chief U.S.Nuclear Regulatory

Commission

Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

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'0 ENCLOSURE Tennessee Valley Authority Browns Ferry Nuclear Plant (BFN)Reply to Notice of Violation (NOV)Inspection

Report Number 2-24"During the Nuclear Regulatory

Commission (NRC)inspection

conducted on June 17-July 17, 1992, a violation of NRC requirements

was identified.

In accordance

with the'General Statement of Policy and Procedure for NRC Enforcement

Actions,'0

CFR Part 2, Appendix C, the violation is listed below: 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires that activities

affecting 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.Instructions, procedures, or drawings shall include appropriate

quantitative

or qualitative

acceptance

criteria for determining

that important activities

have been satisfactorily

accomplished.

Contrary to the above these requirements

were~ot met in that hydrostatic

test pressures used after installation

of corrosion monitors in the residual heat removal service water (RHRSW)system were incorrect.

The RHRSW heat exchanger piping components

were tested to 185 psi instead of the actual design pressure of 450 psi.This was discovered

by the licensee on June 19, 1992, and a limiting condition for operation was entered that resulted in Loop II Containment

Cooling Mode of the RHR System being inoperable.

This condition had existed undetected

for 17 days.During that time other activities

associated

with redundant equipment resulted in plant conditions

that required the plant to be placed in a cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.This is an example of a Severity Level IV Violation (Supplement

I)applicable

to all three units."

0

This violation was a result of ineffective

procedural

contxols.for hydrostatic

testing.Hydrostatic

testing instruction, Modification

Addition Instruction (MAI)4.7A, instructed

the user to calculate test pressure based on the design pressure of the RHRSW piping, but did not stipulate where (or from what document)to obtain the design pressure.This latitude resulted in an error made at the design development

stage propagating

through the design process to installation.

In January 1'991, TVA initiated a workplan to install corrosion monitors at various locations in the RHRSW system.The installation

was completed and tested on June 4, 1992.This ,installation, which included welding sockolets and acc'ess fittings'f

the monitors in place, was hydrostatic

tested at the monitors'ampling

valves at a design pressure of 185 psig.During subsequent

review on a corxosion monitors workplan change, TVA discovered

that the system should have been hydrostatically

tested at a pressure of 450 psig.'hat is, the corrosion monitor sampling valves were underpressurized

when tested.This event occurred when the engineering

personnel that generated the RHRSW modification

criteria for the corrosion monitors design.change notice (DON)incorrectly

listed the system mechanical

requirement (i.e., 185 psig instead of 450 psig).This requirement

was then transferred

to the valve-data sheet as the design pressure.This error led the modification

personnel responsible

for workplan development

to improperly

use the erroneous valve data sheet (as opposed to using the latest available configuration

control diagram)to calculate the test pressure.The Staff noted in the NOV that during the time of this event other activities

associated

with redundant equipment resulted in plant conditions

which required the plant to be placed in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.TVA recognizes

that the RHRSW system, as tested, did not-conform to all aspects of the current licensing basis.However, the sockolets and access fittings of the corrosion monitors were visually inspected and penetrant tested, and the system was successfully

retested at the corxect design pressuxe.Accordingly, plant conditions

did not exist which would have required the plant to be placed in a cold shutdown condition.

t v t k The immediate corrective

steps were to retest the corrosion monitor valves at the correct design pressure of 450 psig, (minimum test pressure 562.5 psig, maximum test pressure 596.25 psig).This retest was successfully

performed on June 20, 1992.

NAI 4.7A has been revised to clarify which source document is required to determine system design pressures for hydrostatic

testing.Also, the modification

criteria for the corrosion monitors DCN and the valve data sheet containing

the erroneous information

were corrected.

t v t t Xia~tma k t th Both the appropriate

engineering

and modification

personnel have reviewed the incident investigation

report for this event.Also, the modifications

personnel responsible

for using the incorrect test pressure document in the development

of the workplan have been counselled.

B v TVA believes that full compliance

has been achieved.

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