ML20095D059

Responds to NRC Re Violations Noted in IE Insp Repts 50-259/84-15,50-260/84-15 & 50-296/84-15.Corrective Actions:Std Practice 14.25 Revised to Require Second Party Verification in Hanging & Removing Clearance Tags

ML20095D059
Person / Time
Site:	Browns Ferry
Issue date:	06/29/1984
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20095C934	List: ML20095D001 ML20095D059
References
NUDOCS 8408230208
Download: ML20095D059 (11)

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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II'

'T:l'2 A9: 58 June 29, 198h 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.'0'Reilly:

Enclosed is our response to R. C.-Lewis' May 23, 1984 letter to H. G. Parris transmitting Inspection Report Nos. 259/84-15, -260/84-15, -296/84-15 regarding activities at our Browns. Ferry Nuclear Plant which appeared to have been in violation of NRC regulations. We have enclosed our response to the Notice of Violation. On June 22, 1984, Ross' Butcher of your staff and Mike Hellums of my staff discussed an extension to June 29,.1984 for submitting this response. If you have any questions, please call Jim Domer at FTS 858-2725.

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

Very truly yours, TENNESSEE VALLEY AUTHORITY

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L. M. Mills, Manager Nuclear Licensing Enclosure 8408230208 840813 PDR ADOCK 05000 Q

An Equal Opportunity Employer

U RESPONSE - NRC INSPECTION REPORT NOS.

50-259/84-15, 50-260/84-15, AND 50-296/84-15 RICHARD C. LEWIS' LETTER TO H. G. PARRIS DATED MAY 23, 1984 ITEM NO. 1 10 CFR 50, Appendix B, Criterion V requires that activities affecting quality shall be prescribed by documented instructions and procedures. The plant clearance procedure (Standard Practice 14.25) for tagout of equipment specifies requirements to be followed in placing equipment in and out of service.

Contrary to the above, the requirements of Standard Practice 14.25 were not met in that tagout clearance procedures were not followed for removing the tag on a piece of equipment when the equipment was returned to service. On April 5, 1984, a unit 1 core spray valve (FCV-75-9) was noted to have a tag on the valve handwheel. The clearance (83-1260) had been cleared and the system returned to service on August 30, 1983 A similar violation was noted in Report 83-60.

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

1.'

Admission or Denial of the Alleged Violation (or Finding)

TVA admits to the violation as stated.

2.

Reasons For the Violations (or Finding) if Admitted Standard Practice 14.25 requires the operator to remove all white clearance tags as a clearance is lifted. This was not done as required by procedure. The red clearance tag was removed, the clearance lifted, and the valve was fully operable. The error was due to personnel error.

3 Corrective Steps Which Have Been Taken and Results Achieved Standard Practice 14.25 is being revised to require second-party verification in both the hanging and removing of clearance tags. The clearance tag was removed from valve FCV-1-75-9.

4.

Corrective Steps Which Will Be Taken to Avoid Further Violations (or

,j Findings)

Implementation of second-party verification requirements and covering the changes in operator supplemental training will avoid further violations.

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Date When Full Compliance Will Be Achieved

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Standard Practice 14.25 will be corrected by July 1, 1984 and operator' 30/9 j

jf training will be completed by September 1, 1984.

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ITEN NO. 2 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 safety of the f acility.

Contrary to the above, this requirement was not met in that Operating Instructions (OI) 32 and 32A, Control / Station Air and Drywell Control Air, do not contain all system valves in the valve lineup checklists'. A randon and partial senple of valves in the reactor building identified that nine valves on unit I were not on any checklist (32-1421, 32-1422, 32-1423, 32-1424, 32-1425, 32-1228, 32-2145, 32-1336, 32-1255). These valves included the supply to the suppression chamber vacuum relief, drywell ventilation supply, and containment inerting valves.

On unit 2, valve 2-32-1755 (HPCI Control Air Supply) is missing from the valve checklist. Examples on unit 3 are 3-32-2276 (HPCI Control Air) 3-32-2224, 3-32-2225 (Containment

~'~~Inerting Control Air).

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

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1. Admission or Denial of the Allemed Violation (or Findina)

TVA admits to the violation as stated.

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2. Reasons For the Violations (or Findina) if Admitted The reason for the violation was due to a f ailure to update valve checkof f list-as modifications were made _to systems 32 and 32A.

3. Corrective Stens Which Hav9 Been Taken and Results Achieved The nine valves _ on unit l', unit 2 HPCI control air supply valve (2 1755), unit 3 HPCI control air valve (3-32-2276), and containment inerting control air valves (3-32-2224 and 3-32-2225) are currently being placed in 0I-32 and 32A. A complete walkdown of the Control Air System is being conducted and the system 32 and 32A drawings are being changed to reflect the actual configuration. The OI valve checklist will be changed when drawings 'are revised.

4. Corrective Steos Which Will Be Taken to Avoid Further Violations (or Findinas)

The Control Air System has been walked down by two Operations personnel and the system drawing and valve checklist is being updated from this physical verification. From this update and the approved procedures now in place, this problem will be eliminated in the future.

5. Date When Full Como11ance Will Be Achieved The listed valves will be corrected by July 2,1984, and a full system evaluation will be completed by December 19, 1984.

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, ITEN NO. 3 10 CFR 50, Appendix B, Criterion V requires that activities affec' ting quality shall be prescribed by documented instructions or procedures.

Browns Ferry Standard Practice 8.3 requires that plant modifications be completed by the use of a workplan.

Contrary to the above, the requirement was not met in that on April 24, 1984, old fuel racks were removed from the unit 2 fuel pool without the use

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of a detailed or adequate workplan to address the task action requirements or procedural steps.

This is a Severity Level IV Violation (Supplement I) applicable to unit 2.

1. Admission or Denial of the Allemed Violation (or Findina)

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'IVA admits to the violation as stated.

2. Reasons For the Violations (or Findina) if Admitted Work was performed with an approved workplan although complete detailed,

instructions were not provided.

Instructions were worded in such a manner that they were vague and could be misinterpreted.

3. Corrective Stoos Which Have Been Taken and Results Achieved The workplan was revised to clarify work instructions.

4. Corrective Steps Which Will Be Taken to Avoid Further Violatioes (or Findinas)

Individual personnel responsibilities are being redefined as part of the Regulatory Performance Improvement Program (RPIP), which will result in a more thorough preparation and review of instructions prior.

to their approval.

5.

Date When Full Como11ance Will Be Achieved l'

Full compliance was achieved on June 2,1984.

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ITEN NO. 4.a 10 CFR 50, Appendix B, Criterion V requires that activities affecting

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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 lastructions, procedures, or-d drewinas.

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Contrary to the above, this requirement was not met in that control air system as-constructed drawings 47W847-9, -10, and -11 do not reflect the control air systems in the plant. On unit i valve 1-32-1278, isolation to PC-68-106, is not on the drawing.

Isolation val've to FCV-70-1 is labeled 1-32-2554 in the plant but is not numbered on the drawing.

Isolation valve to FCV-68-106 is labeled 1-32-1279 but'is not numbered on the drawing. On unit 2, differences between plant valve identification tags and the drawings are 1278 (plant) versus 2121 (drawing),1279 (plant) versus 2122 (drawles),1894 (plant) versus no number (drawing), no label' (plant) versus 2133 (drawing),1397 (plant) versus 2132 (drawing), and 1781 (plant) versus 2139 (drawing). On unit 3, the drawing does not show the vcive between 2121, 2122 and 6%,

2322. Valve 2133 on the drawing is not labeled in the plant.

Item 4.a.

_.,, _ 1.

Admission or Denial of the Allemed Violation (or Findina)

'IVA admits the violation as stated.

2.

Reasons For the Violations (or Findina) if Admitted The control air system was originally field fabricated and installed without adequately approved drawings.

3.

Corrective Steos Which Have Been Taken and Results Achieved A total system walkdown is being performed by plant personnel for the control air system flow diagrams to reflect the as-constructed status.

4.

CorrectiveSteosWhichWillBeTakentokvoidFurtherViolations(or Findinas)

Accessible portions of this' system have been walked down, drawings are being as-constructed, and a schedule is being developed for inspection of inacecssible pt,rtion of each unit. Final completion of RPIP loor-term, item 2.1 (RPIP 2-1) (Resolution of open/ incomplete ECNs, wrkplans, as-constructed drawings) is estimated to be January 1, i-1986.

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Date When Full Como11ance Will Be Achieved l

Full compliance will be achieved by January 1,1986.

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Item No. 4

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I 10 Cc'It 50, Appendix B, Criterion V requires that activities affecting gestity shall be prescribed by documented instructions, procedures, or

]y drawings of a type appropriate to the circumstances and shall be I

accomplished in accordance with these instructions, procedures, or dravings.

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Contrary to the above, this requirement was not met in that the following discrepancies in plant drawings, pressure switch se'tpoints, and annunciator were found as related to the fire protection area:

(1)

Browns Ferry Instrument Tabulation (drawing 47B601-026, page 40) gives the setpoint of pressure switch PS-26-44 as 120 psi for the header pressure. As constructed drawing 45N644-1 gives the setting as 100 psi.

(2) Design Change Request 1581, R1 dated September 23, 1978 gives the setting of pressure switch PS-26-44A as 50 psis, but a setting of 60 psi is shown on drawing 45N644-1 and 35N731-9.

(3) Annunciation for ' Fire Protection Water Supply On' supplied from PS-26-44 was changed to ' Raw Service Water Pressure Low' supplied from PS-26-44A.

Logic diagram 47W611-26-13 incorrectly shows the alarm being supplied from PS-26-44.

Also, the control diagram for the annunciator system, 47W610-55-2, incorrectly shows the title and pressure switch number for the annunciator as PS-26-44, ' Fire Protection Water Supply On.'

(4) The installation of PS-26-44A is not correctly reflected in plant drawings. Flow diagram 47W836-1 shows an isolation valve for PS-26-44 but no valve for PS-26-44 A.

A valve is installed in the system. Panel drawing 47W600-51 does not show PS-26-44A on panel 25-139.

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

ITEM NO. 4b 1.

Admission or Denial of the Allemed Violation (or Findina)

TVA admits the violation occurred as stated.

2.

Reasons For the Violations (or Findina) if Admitted The as-constructed instrument tabnistion (drawing 47B601-026, page 40) was as-constructed incorrectly. Modification Change Request No. 891 was implemented by workplan 5445 without as-constructing all affected drawings. Drawings 45N644-1 and 35N731-9 were incorrectly as-constructed.

3.

_C_g.trective Steos Which Have Been Taken and Resnits Achieved Engineering Change Notice '(EOO P0210 has been issued by Engineering Design to correct the as-constructed drawing discrepancies and a j

workplan will be prepared to implement this remaining modification m

(see attachment memorandum).

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Corrective Steos Which Will Be Taken to Avoid Further Violations (or Findinas)

ECN P0210 has been issued to correct these drawing discrepan'cles and a closer review of design change requests will be performed to avoid further violations.

5.

Date When Full Conoliance Will Be Achieved Full compliance will be achieved by March 1,1985.

ITEN NO. 5 Technical Specification 6.3.A.6 requires that detailed written procedures for surveillance and testing requirements be prepared, approved, and adhered to.

Technical Specification 4.11.A.1.g requires that a fire protection building hydraulic performance verification be performed tri-annually.

Contrary to the above, the requirement was not met in that Surveillance Instruction No. 4.11.A.1 3 was inadequate to assure that reactor building hydraulic performance was as described in the fire protection system design.

bases, the post-modification test (PT-13-1) or the Browns Ferry Fire Recovery Plan, Part I, Section A of 1976.

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

1

1. Admission or Denial of the A11eaed Violation (or Findina)

TVA admits a violation occurred with clarification as described in (2).

2. Reasons For the Violations (or Findina) if Admitted Technical Specification 4.11.A.1 3 does require a building hydraulic performance verification be performed tri-annually. Technical Specification 3.11.A.9 requires that the fire protection system be capable of supplying the individus1 loads listed in Table 3.11.A.

Surveillance Instruction 4.11.A.1 3 adequately assures that the

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individual systems are capable of supplying the individual loads listed in Table 3.11. A.

Therefore, detailed written procedures for surveillance and testing requirements were prepared, approved, and adhered to which met the requirements of Technical Specifications 3.11. A.9, 4.11. A.1 3, and 6.3. A.6.

1 However, TVA does admit that the flows listed in Table 3.11.A. do not seet the commitment contained in the Browns Ferry Fire Recovery Plan, Part I, Section A, Revision 6, Page 41, paragraph 5.2.1.2(8) which J

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states 'the piping will be hydraulically designed to provide the -

pressure neuessary at the nozzles to supply the water density specified

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in (1) above with one 1-1/2-inch hose connection being used simul tane ously. '

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Corrective Steps Which Have Been Taken and Results Achieved A Special Test (ST 8409R1) was conducted to verify that the piping

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will provide.the pressure necessary at the nozzles to supply the water density specified in the Browns Ferry Fire Recovery Plan, Part I, Section A, Revision 6, Page 40, Paragraph 5.2.1.2(1) with one 1-1/2-inch hose connection being used simultaneously. All fixed cable tray water spray systems passed ST 8409R1.

4.

Corrective Stens Which Will Be Taken to Avoid Further Violations (or Findinas)

TVA will conduct a design study to re-evaluate the design basis, the required flow and pressures, the required testing frequencies and the adequacy of test locations for the fixed cable tray water spray systems installed in accordance with the Browns Ferry Fire Recovery Plan. Table 3.11.A. and Surveillance Instruction 4.11. A.1.g will be

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revised based on the results of the design study.

5.

Date When Full Coun11ance Will Be Achieved Full compliance will be achieved by March 2,1985.

ITEN NO. 6 10 CFR 50, Appendix B, Criterion V requires that activities affecting quality shall be accomplished lu accordance with instructions, procedures, and drawings.

Operating Instruction 32A (Drywell Control Air System) specified the required valve lineup for the drywell control air system.

Operating Instruction 24 (Drywell Delta-Pressure Control Air Compressor System) specifies the required valve lineup for the drywell delta pressure control air compressor system.

a.

Contrary to the above, th's requirement was not met in that on April 5, 1984, drywell control air return filter bypass valve 1-32-2525 was found mispositioned in the open position. The master valve status checklist indicated the valve was shut which was contrary to the as-found position.

b.

Contrary to the above, the requirement was not met in the April 10, 1984, drywell delta pressure control air compressor temperature regulatory bypass valve 2-24-876 was found mispositioned in the open po si tion.

OI-24 requires the valve to be shut. The master valve status ' checklist indicated the valve was shut which was contrary to the as-found position.

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

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1. Admission or Denial of the Allemed Violation (or Findina)

TVA admits the violation as stated.

2. Reasons For the Violations (or Findina) if Admitted Falinre to follow procedures was the reason for the violation.

3. Corrective Stens Which Have Been Taken and Resnits Achieved Valve 1-32-2525 was realigned to the closed position as required by Operating Instruction 32A valve checklist. An abnormal status sheet was placed in the front of the master checklist to show that the bypass valve (2-24-876) was lef t in the open position to help in contro111ag the temperature on the delta P air compressor.

4. Corrective Steos Which Will Be Taken to Avoid Further Violations (or Findinas)

To prevent future problems of valve misalignment and documentation of abnormal valve alignment, the assistant unit operators have been assigned to review system status checklist more frequently to ensure the system status checklist reflect actual system status. Operational personnel will receive supplementary training which will cover these violations and ensure proper system status is maintained per Operating Instruction Letter 43.

5. Date When Full Comollance Will Be Achieved Full compliance will be achieved by July 24, 1984.

ITEM NO. 7 10 CFR 50, Appendix B, Criterion I requires that a program for inspection of activities affecting quality shall be established and executed to verify conformance with documented instructions, procedures, and drawings for accamp11shing the activity.

Contrary to the above, the requirement was not met as related to Mechanical

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Maintenance Instruction (MMI) 125 (Inspection, Testing, and Maintenance of Monorail Systems, Underhang Cranes, and Overhead Hoists) and MMI 130 (Mobile Cranes and Forklists, Inspection, Testing, and Preventative Maintenance) as indicated by the examples below.

l Nechanical Maintenance' Instruction (NMI) 125 requires a periodic a.

inspection of monorail systems, naderhang cranes, and hand-chain powered overhead hoists to be conducted on idle (over six months) equipment. No evidence was available for review to indicate this inspection was being scheduled or completed as required.

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MMI-125, Appendix 2, requires a frequent (not defined) inspection be conducted on hand powered overhead hoists. The hooks are to be checked to ascertain the hook throat opening was not more than 15 percent greater than normal throat opening. The procedure did not specify the normal throat opening and no evidence that the inspection had even been conducted was available for review.

Several mechanical engineers / technicians interviewed did not know what the normal throat opening wonid be for various size hooks. The procedure specifically deleted any data sheet requirements.

c.

MMI-130 requires wire rope inspections to include a check for proper rope reeving. The reeving of individual cranes was not listed in the procedure or known by mechanical craft personnel, d.

MMI-130, data sheet 7, monthly wire rope inspection, is inconclusive on required signoff (one yes/no signoff for two determinants, step 1.c.) and does not address a signoff for each requirement in the procedure text. (No signoff to verify rope reeving.)

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

1. Admission or Denial of the Allemed Violation (or Findina)

TVA admits to the violation as stated.

2. Reasons For the Violations (or Findina) if Admitted Inadequate procedures were the reason for the violation.

3. Corrective Steos Which Have Been Taken and Resnits Achieved A crane engineering specialist reviewed all the items inspected by MMI-125 and MMI-130 instructions and found the equipment to be non-critical components.

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4. Corrective Sters Which Will Be Taken to Avoid Further Violaticas (or l

Findinas) l The procedures were completely rewritten and will be issued as Mechanical Maintenance Guidelines because they cover non-critical items. The items will also be incorporated into the computerized preventative maintenance program to avoid further violations.

5.~Date When Full Como11ance Will Be Achieved Full compliance will be schieved by July 16, 1984 when MMI-125 and MMI-

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1 130 have been revised and changed to guidelines.

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ITEN NO. 8 10 CFR 50, Appendix B, Criterion VI requires that measures shall.be established to control the issuance of documents, such as drawing's, including changes thereto, which prescribe all activities affecting quality. These measures shall assure that documents are distributed to and used at the location where the prescribed activity is performed. Browns Ferry Standard Practice 2.5 implements the drawing control procedures and requir eme nt s.

j Contrary to the above, the requirements of Standard Practice 2.5 were not

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met in that control drawing 47W847-10 in the Technical Support Center (TSC) was of the wrong revision. The current revision is revision 3 where as revision 2 was found in the TSC control drawings.

This is a Severity Level V violation (Supplement I) applicable to all

..___ units.

1. Admission or Denial of the Allemed Violation (or Findina)

TVA admits the violation occurred as stated.

2. Reasons For the Vloistions (or Findina) if Admitted The reason for the violation was personnel error on the part of a issue clerk.

An out-dated copy of drawing 47W847-10 was in the TSC file s.

3. Corrective Steos which Have Been Taken and Results Achieved The out-dated drawing was removed and the current revision of drawing 47W847-10 placed in the TSC.

4. Corrective Stoos Which Wil'1 Be Taken to Avoid Further Violations (or Findinas)

All Drawing Control Center issue clerks were cautioned about the need for absolute accuracy in the drawing filing process.

5. Date When Full Como11ance Will Be Achieved Full compliance was achieved on April 19, 1984.

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