ML20101T435

Responds to NRC Re Violations Noted in Insp Repts 50-259/84-26,50-260/84-26 & 50-296/84-26.Corrective Actions: Deficient Pumps Removed from Svc for Maint.Training Conducted

ML20101T435
Person / Time
Site:	Browns Ferry
Issue date:	11/16/1984
From:	Hufham J TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20101T404	List: ML20101T417 ML20101T435
References
NUDOCS 8502060166
Download: ML20101T435 (8)

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. TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374ol 400 Chestnut Street Tower II bllla;r 2I p 3. 38 November 16, 1984 U.S. Nuclear Regulatory Commission >

Region II ATTN: James P. O'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

Dear Mr. O'Reilly:

Enclosed is our response to R. C. Lewis' October 17, 1984 letter to H. G. Parris transmitting IE Inspection Report Nos. 50-259/84-26,

-260/84-26, -296/84-26 for our Browns Ferry Nuclear Plant which appeared to have been in violation of NRC regulations. We have the responses to the Notice of Violation as enclosure 1 and the Notice of Deviation as enclosure 2. If you have any questions, please call Jim Domer at FTS 858-2725. .

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

Very truly yours, i

TENNESSEE VALLEY AUTHORITY

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- J, . Huh, anager L:. ensing and hegulations Enclosure l

8502060166 850117 PDR ADOCK 05000259 0 PDR l

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An Equal Opportunity Employer

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ENCLOSURE 1 *

• NRC INSPECTION REPORT NOS.

50-259/84-26, 50-260/84-26, AND 50-296/84-26 R. C. LENIS' S LETIER TO H. G. PARRIS Il ii

• DATED 0CTOBER 17 , 1984 il RESPONSE TO NOTICE OF VIOLATION i.

The f ollowing violations were identified during an inspection conducted on June 26 - July 27,1984. ':

,l The Severity Levels were assigned in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C) .

> Item 1 - (259. 260/84-26-02)

Technical Specification (TS) 3.5.C.6 requires that if TN 3.5.C.2 through 3.5.C.5 are not met, an orderly shutdown shall be initiated and the unit placed in the cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Technical Specification 3.5.C.2 requires a minimum of four operable Residual Heat Removal Service Water (RHRSW) pumps assigned to RHRSW service during reactor power operation of two units.

Contrary to the above, this requirement was not met on July 20,1984 in l l

that an orderly shutdown was not initiated when TS 3.5.C.2 was not met for the required number of operable residual heat removal service water pumps. l Unit I remained at 100% power and unit 2 at 55% power during this period.

This is a Severity Level IV violation (Supplement I) applicable to Units 1 l

and 2.

1. Admission or Denial of the Allened Violation )

l TVA admits the alleged violation as stated. l

2. Reasons for the Violation l

RRRSW pumps B1, B2, C1 and D1 were declared inoperable' on July 20, 1984 '

at 9 :45 p.m. for f ailing to meet pump performance criteria of ASME Section II, Pump and Valve Testing. They met Technical Specification requirements for pump operability at all times except when tagged out for maintenance adjustments. Diesel generator A had previously been removed from service to accommodate installation of throttling valves as committed in our response to an earlier NRC violation (84-01-01) .

Therefore, two additional pumps (Al and A2) were considered to be inoperable because the 1 A diesel generator was inoperable, but plant personnel misinterpreted Technical Specification 1.C.2. which states that when a system, subsystem, train, component or device is determined to be inoperable because its onsite power source is inoperable. .. it may be considered operable if its off site power source is available and f

its redundant equipment is operable.

Based on this conclusion, the f acility was erroneously assessed as being in a 'seven-day LCO rather than 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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.' Pags 2 3., Corrective Stens Which Have Been Taken and Results Achieved The deficlent pumps were sequentially removed from service for maintenance. All pumps were restored to fully operable status within l l

13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> af ter identification of the problem. Live time training was held with all licensed personnel on the event. j k

, 4. Corrective Stens Which Will Be Taken to Avoid Further Violations l

Standard Practice BF 12.20 is formulated to assist operating personnel in interpretation of definition 1.C.2 of the Technical Specifications.

Use of this Standard Practice is being incorporated into the operator and shift technical advisor retraining program.

5. Date When Full Comoliance Will Be Achieved Full compliance was achieved August 29, 1984.

Item 2 (259. 260/84-26-04)

Technical Specification 4.5.C.4 requires that when it is determined that '

one of the RHRSW pumps supplying standby cooling is inoperable at a time a when operability is required, the operable RHRSW pump on the same header and its associated diesel generator and the Residual Heat Removal (RHR) i heat exchanger header and associated essential control valves shall be demonstrated to be operable immediately. Plant Surveillance Instruction

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j 4.5.C., RERSW System and Emergency Equipment Cooling Water System Valve Operability Test (Common), states to perform Section 4.5.C.1 (Valve 23-57 l only) to demonstrate operability.

l Contrary to the above, this requirement was not met in that when the B1, l B2, and D1 RHRSW pumps were declared inoperable on July 20, 1984, the 1

associated essential control valves (valve 23-57) were not demonstrated to

• be operable immediately and were never tested while the pumps were i

inoperable. Unit I was operating at 100% power and unit 2 at 55% power.

This is a Severity Level IV violation (Supplement I) applicable to units 1 and 2.

1. ' Admission or Denial of the A11eaed Violation TVA admits to the violation as stated.

2. Reasons For the Violations Due to a personnel error and a poorly written procedure, . valve FCV 23-57 for units 1 and 2 was not tested when RHRSW pumps supplying standby cooling were determined to be inoperable.

3. Corrective Stens Which Have Been Taken and Results Achieved t

i Live time training was conducted for operators concerning

RHRSW operability requirements. The Surveillance Instruction was also '

clarified.

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. 4. . Corrective Stens Which Have Been Taken and Results Achieved The training will avoid future violations.

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5. Date When Full Coun11ance Will Be Achieved s

Full compliance has been achieved. l Item 3 (259, 260/84-26-05) l Technical Specification 3.7.E.1 requires that both Control Room Emergency Ventilation (CREV). pressurization systems and the diesel generators l required for their operation shall be operable at all times when any [

reactor vessel contains irradiated fuel. Technical Specification 3.7.E.3 --

states that from and af ter the date that one of the CREV is made or found to be inoperable for any reason, reactor operation is permissible only during the succeeding 7 days.

Contrary to the above, this requirmnent was not met in that on July 25, 1984, the 'B' CREV system suction automatic damper was found disconnected. At the same time the diesel generator ' A' which supplies j I

power to the redundant ' A' CREV system, was out of service for maintenance. Units 1 and 2 were at power during this time. The CREV 'B' system was last known to be operable during surveillance testing on July 2, 19 84 .

This is a Severity Level IV violation (Supplement I) applies to units 1 and 2.

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1. Admission or Denial of the A11eaed Violation i I

I TVA admits the alleged violation as stated.

2. Reasons For the Violations The damper (FCO-31-152) had become disconnected af ter a set screw failed to remain tight enough to secure the linkage. The reason the set screw loosened could not be determined. At 1243 hours0.0144 days <br />0.345 hours <br />0.00206 weeks <br />4.729615e-4 months <br /> on July 25, 1984, CREV 'B' damper was found inoperable due to the damper's linkage being disconnected. At 1425 the same day, . the linkage was replaced and SI 4.7.E-5 completed. . TS 3.7.E.3 states that f rom and af ter the date that one of the CREV is made or found to be inoperable for any reason, reactor operation is permissible only during the succeeding 7 days. TS 3.8.E.4 states that if TS 3.7.E.3 cannot be met, reactor shutdown shall be initiated and all reactors shall be in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for reactor operations and refueling operation shall be terminated

'within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The event caused the plant to enter the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> LOO permitted by TS 3.7.E.4 above for less than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

3. Corrective Stens Which Have Been Taken and Results Achieved The damper linkage for CREV train 'B' was raplaced with a threaded rod and lock nuts in addition to the set screw.

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Corrective Stens Which Will Be Taken to Avoid Further Violations The damper linkage for CREV train.' A' was replaced with a threaded rod and lock nuts in addition to the set screw to prevent this fran happening in the future. Test procedures which require manipulation of the damper linkage have been revised to include double verification that the linkage was correctly connected af ter testing is performed.

5. Date When Full Comoliance Will Be Achieved Full compliance was achieved on September 2,1984, when both linkages were modified as stated above.

Item 4 (260/84-26-01) l 10 CFR 50, Appendix B, Criterion V requires that activities affecting quality shall be accomplished in accordance with prescribed procedures.

Browns Ferry Standard Practice 14.25 implements the plant tag clearance procedures to be adhered to during plant operations.

Contrary to the above, the requirement was not met in that on July 9,1984, it was found that clearance 84-412 was incorrectly placed such that the hold order tag was valve HCV 2-2-1260 (demineralized water to torus level instrumentation) was hung on the incorrect valve and not placed on HCV 2-2-1260 as required by the clearance order. Additionally, the clearance order for valve 2-2-1260 had been second party verified incorrectly such that the second party verification was not effective in noting the error.

This Severity Level IV violation (Supplement I) applicable to unit 2.

1. Admission or Denial of the Allemed Violation TVA adnits to the violation but with the following clarifications as stated in reasons for the violation.

2. Reasons for the Violation The violation occurred due to inadequate drawings and valve identification when the hold order was established. Clearance 84-412 was incorrectly placed. No second party verification was required when the clearance was initially issued.

3. Corrective Stens Which Have Been Taken and Results Achieved The hold order clearance was reestablished correctly with second party i verification and drawing changes initiated to show proper valve configurations. Stsudard Practice BF 14.25 was revised to require second party signoff on the condensate storage and supply system as well as all safety-related systems. Live time training was conducted to all operation personnel on the revision to Standard Practice BF 14.25. Also, the Standard Practice was changed to address proper clearance procedures to be followed for situations involving unmarked valves.

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• 4, , Corrective Stens Which Will Be Taken to Avoid Further Violations Live time training was conducted from July 25, 19 84, to October 5,1984, to prevent further violations.

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5. Date When Full Comoliance Will Be Achieved Full compliance was achieved Octobe'r 5,1984, when the Standard I

Practice BF 14.25 was revised and all involved personnel trained on the revised material.

Item 5 (259, 260. 296/84-26-03) i Technical Specification 6.3.A.1 requires that detailed written procedures ~

including applicable checkoff lists shall be prepared,' approved, and adhered to for normal startup, operation and shutdown of the reactor and of all systems and components involving nuclear saf ety of the f acility.

. Contrary to the above, this requirement was not met in that Standard i Practice 12.20 (BF 12.20), Actions Required by Technical Specification Definition 1.C.2-LCO, was not followed and form BF 126 not checked to

clarify the applicable limiting condition for operation. For example

a. Form BF 126 was not checked when residual heat removal service water pumps were declared inoperable on July 20, 1984, while a diesel generator was inoperable. Unit I was operating at 100% power and unit 2 at 55% power.

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b. A review of plant conditions and available records for the past f ew months revealed that form BF 126 was never completed at times when a diesel generator was declared inoperable as indicated below:

4 Diesel Generator Timg Date B 6 : 15 p. m. 6/ 16/84 D 5:50 a.m. 6/ 18/ 84 3EA 1:15 a.m. 6/08/ 84

) B 11:40 p.m. 5/3 0/ 84 C 8:20 a.m. 5/28/84

' A form dated November 2,1983, for the 'C' diesel was not signed by the shif t engineer or the operations supervisor as required. .

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

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1. Admission or Denial of the A11eaed Violation TVA admits to the violation as stated.

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Reasons For the Violation The violation occurred due to the f ailure to properly use Standard l Practice form BF 126 to check operability of redundant equipment in a i forward and reverse flow path. This was due to inadequa te training on I the content and usage of Standard Practice BF 12.20.

3. Corrective Stens Which Have Been Taken and Results Achieved Live time training was conducted for all licensee individuals concerning RHRSW operability and Standard Practice BF 12.20 and the use  ;

of BF 126,

4. Corrective Stens Which Will Be Taken to Avoid Further Violations ~~

Live time training was conducted from July 26, 1984, to August 29, 1984, to prevent reoccurrence.

5. Date When Full Como11ance Will Be Achieved Full compliance was achieved August 29, 1984, when the training was completed.

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Ptgn 7 ENCLOSURE 2 REPSONSE TO NOTICE OF DEVIATION Item 1 (259/84-26-06)

In Reportable Occurrence Report BFRO-50-259/83068 RI (RHR pump motor failure) dated May 25, 1984, it was stated that a follow-up report to address the failure mode and recurrence control would be issued by July 16, 1984.

Contrary to the above, the follow-up report was not issued until July 24,

- 1984, after the inspector informed the licensee that the report was not ~ ~

issued. Discussions with plant personnel revealed that an administrative error resulted in the report not being issued. The report had not been adequately tracked to ensure the final report was issued.

This deviation is applicable to unit 1.

1. Admission or Denial of the Alleged Violation (or Finding)

I TVA admits the alleged deviation as stated.

2. Reasons For the Violations (or Finding) if Admitted The reason for the deviation was miscommunication between scheduler and schedulee. Compliance scheduled the item as due July 16, 1984, and gave notice to the cognizant section as track item #1411 two weeks before July 16, 1984. The item failed to be caught on the overdue printout by the responsible Compliance Engineer.

3 Date When Full Compliance Will Be Achieved i

Personnel involved were counseled regarding proper tracking procedures and full compliance was achieved on July 24, 1984.

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