ML20070B137
| ML20070B137 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/22/1982 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20070B139 | List: |
| References | |
| NUDOCS 8212090461 | |
| Download: ML20070B137 (5) | |
Text
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USNPCfEENE$SNEE VALLEY AUTHORITY m anw, u _m.
CH A TTANOOGA. TENNESSEE 37401 400 Che nut Street Tower II 82 0CT 28 AS: I October 22, 1982 U.S. Nuclear Regulatory Commission Region II ATTN: James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Dear Mr. O'.ailly:
Enclosed is our response to R. C. Lewis' September 21, 1982 letter to H. G. Parris transmitting Inspection Report Nos. 50-259/82-24,
-260/82-24, -296/82-24 regarding activities at our Browns Ferry Nuclear Plant which appeared to have been in violation of NRC regulations. We have enclosed our response to Appendix A, Notice of Violation. The inspector's concerns expressed on page 4 of the
" Details" regarding Violation C are being evaluated and will be provided by January 2, 1983 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 L. M.
ills, Manager Nuclear Licens'ing Enclosure 8212090461 821112 PDR ADOCK 05000259 G
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RESPONSE - NRC INSPECTION REPORT NOS.
50-259/82-24, 50-260/82-24, AND 50-296/82-24 R. C. LEWIS' LETTER TO H. G. PARRIS DATED SEPTEMBER 21, 1982 Item A - (296/82-24-03) 10 CFR 50, Appendix B Criterion XI, as implemented by TVA Topical Report 75-1, paragraph 17.2.11, requires that a test program be established to assure that all testing required to demonstrate that components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate requirements and acceptance limits.
Contrary to the above, the requirement was not met in that post maintenance testing was not conducted on the scram pilot valves and the test criteria, which had been previously established, did not incorporate requirements and acceptance limits.
This is a Severity Level IV Violation (Supplement I.) and is applicable to Unit 3 1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted The text of Mechanical Maintenance Instruction (MMI) 28, Control Rod Drive Hydraulic Unit Module (Repair, Removal, and Replacement), did not refer to Data Sheet 28.4 which contained the requirement for postmaintenance functional testing. This was an oversight in the original preparation of the instruction.
3 Corrective Steps Which Have Been Taken and the Results Achieved The scram pilot valves were subsequently te,sted with the reactor at 33-percent power during the course of control rod scram time testing.
j All valves were acceptable.
MMI-28 was revised October 5, 1982 to include requirements for postmaintenance functional testing.
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4.
Corrective Steps Which Will Be Taken To Avoid Further Violations l
No further corrective action is required.
5.
Date When Full Compliance Will Be Achieved I
Full compliance was achieved on October 5, 1982 when MMI-28 was revised.
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i 2-Iten B-Technical Specification 4.8.B.1.a requires that for effluent streans.having continuous nonitoring capability, the activity and flow rateishall be monitored and recorded to enable release rates of,eross radioactivity to be deternined on an hourly basis.
Contrary to the above, the requirenent was.not net in that:
1.
On August 19,1982 at 10:00 a.n. the sample bose to the Unit 3 Continuous Air Ponitor (CAM) RM 90-250, which monitors the Turbine Building, Reactor Ruilding and Refueling Floor ventilation exhaust, was.
determined to-have been disconnected. The length of time the sanple hose was disconnected could not be determined; however, the last time the CAM had a background check performed was on August 17,1082 at 1900. The background check requires the sanple hose to be disconnected fron the CAM.
2.
On August 25, 1982 at 12:30 p.m. the sanple bose to the Unit 1 Continuous Air Monitor (CAP) RM 1-90-250, which conitors the Turbine Buildin't, Reactor Building and Refueling Floor ventilation exhaust, was observed disconnected. The length of tine the sample bose was disconnected could not he determined; however, the lost time the CAM hoses vere verified installed uns during a background check on August 24, 1982.
This is a Severity Level IV Violation (Supplement T.) and is applicable to Unit 1 and Unit 3.
M (206/82-24-01)
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1.
Adrission or Denial of the A11eced Violation
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TVA admits the violation occurred as stated.
2.
Densons for ths Violation if Admitted The last authorized re3 oval of the continuous air nonitor (CAM) hose was performed by a radiochemical laboratory analyst (RLA). Phen the event was discussed with the'RLA who last checked the CA't, he could not verify that the hose was reconnected when he left. No verification procedure existed to docunent that the RLA. reconnected the bnse.
3.
Cor"ective Steos Phich Fave Paen Tnken and the Pesults Achieved All RLAs were instructed to ensure that the hose is reconnected upon completion of the daily source and background check.
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.... A new data sheet (Surveillance Instruction (SI) h.R.F.1.a.3) was added to SI 4.8.B.1.a.'1 on August 26, 1982. This data sheet nust he signed by the RLA verifying the CAM has been returned to normal (turned on with hose rennected) after performing daily source and hackgenund check.
4.
Correetive Stens Which Will ne Taken To Avoid Further Viointions No further corrective action is required.
5.
Date When Full Conoliance Mill Be Achieved Full compliance was achieved on August 26, 1982 when the new data sheet was implemented to ensure verification of CAM hoses.
B-2-(250/82-2451) 1.
Admission or Denial of the Alleged violation TVA admits the violation occurred as stated.
2.
Pennons for the Violation if Admitted This violation was caused by a faulty Chicago fitting used to connect the inlet sanole line to the CAM. Upon closer inspection it was discovered that the safety clips used to hold the fitting in place were missing. The fitting was worn from repeated use and would easily core loose when jarred, even though it appeared to be connected.
3 Corrective Stens Which Have Aeen Taken and the Results Achieved The inlet sanple line was inmediately reconnected to the CAM uoon
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discovery. A new hose, fitting, and safety clips were installed on August 31, 1982.
4.
Corrective Stens "hich Nill Pe Taken To Avoid Further Violations No additional corrective action is required.
5.
Date " hen Full Connliance Will Be Achieved Full conpliance was achieved on August 31, 1982 when a new hose, fitting, and safety clips were installed.
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_4 Item C - (259/82-24-02)
Technical Specification 6.3.A.6 requires that detailed written procedures shall be adhered to for surveillance and testing requirements.
Surveillance Instruction (SI-2), Instrument Checks and Observations, requires that if a recirculation pump speed is unavailable, then both recirculation pump generator speeds shall be recorded daily.
Contrary to the above, the requirement was not met in that from July 18 to July 25, 1982 recirculation pump speed "B" was unavailable and pump generator speeds were not recorded as required.
This is a Severity Level V Violation (Supplement I.) and is 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 The operators failed to use the reference note in SI-2, Instrument Checks and Observations, as referenced when a speed indicator has failed.
It should be noted that technical specification 4.6.F.1 is obsolete but has not been previously taken out due to oversight. Therefore, there was absolutely no nuc1'ar safety implication involved in this event.
3 Corrective Steps Which Have Been Taken and the Results Achieved Operators have been instructed to follow instructions of SI-2.0 for recirculation pump speed documentation.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations No fu. ther corrective actions are required; however, a proposed change to delete the obsolete technical specification requirement is being prepared.
5.
Date When Full Compliance Will Be Achieved Full compliance was achieved Jtiy 26, 1982, when the operators were instructed to adhere to SI-2.0 instructions.
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