IR 05000220/2003001
| ML18029A786 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Nine Mile Point  |
| Issue date: | 07/22/1985 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Parris H TENNESSEE VALLEY AUTHORITY |
| Shared Package | |
| ML18029A787 | List: |
| References | |
| EA-85-051, EA-85-51, NUDOCS 8508140236 | |
| Download: ML18029A786 (6) | |
Text
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uNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N,W.
ATLANTA,GEORGIA 30323 JUL 22 $85 Tennessee Valle~~hority ATTN:
Mr. H.
G. Parris Manager of Power and Engineering 500A Chestnut Street Tower II Chattanooga, TN 37401 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES:
EA 85-51 (INSPECTION REPORT NOS. 50-259/85-1, 50"260/85-13, AND 50"296/85-13)
A specia'l safety inspection was conducted on February 20 - March 1, 1985 of act1v1ties authorized by NRC Operating License Nos.
DPR-33, DPR-52, and DPR-68 for the Browns Ferry Nuclear Plant; The inspection included a review of reactor vessel water level indication anomalies that occurred during the Unit 3 startup on February 13, 1985.
As a result of this inspection, failures to comply with NRC regulatory requirements were identified and, accordingly, an Enforcement Conference to discuss these matters was held in the NRC Region II Office on March 14, 1985.
The inspection report was issued separately on March 28, 1985.
Item A in the enclosed Notice of ViolatioII and Proposed Imposition of Civil Penalties involves the failure to meet the Technical Specification requirements for reactor vessel water level instrumentation operability during a reactor startup on February 13, 1985.
This violation is considered serious by the NRC because your operators had sufficient information to indicate that important instrumentation was inoperable and, instead of identifying and fixing the cause of the problem, they continued with the February 13, 1985 reactor startup.
Specifically, due to error inherent at low reactor pressures and temperatures, two Yarway water level instruments indicated a reactor vessel water level about 25" greater than the actual vessel water level.
Two of the three GEMAC water level instruments were indicating a reactor vessel water level of 37", and the third GEMAC water level instrument was indicating 10".
The operators believed the GEMAC instrument indicating 10" was erroneous because the other two were approximately in numerical agreement with the.Yarways.
Even when a half scram occurred as a result of low reactor water level, the operators failed to determine which instruments were providing correct reactor water level indicytion, The NRC believes reactor operations should have been suspended until the problem was corrected or reliable reactor vessel water level indication was reestablished.
Such action is necessary because the errors in the GEMAC instruments were caused by a malfunctioning reference leg which was common to the Barton water level instruments and which degraded two channels of the one of two taken twice logic associated with the reactor water level scram in the Reactor Protection System.
Instead, your operators reset the half scram by raising the reactor vessel water level in manual control, and continued power escalation.
The NRC considers the'act that rod withdrawal for heatup continued to be a significant concern, particularly since your Plant Superintendent for Operations and Operations Supervisor became aware of this event approximately at CERTIFIED MAIL RETURN RECEIPT RE UESTED 850814023
Tennessee Val 1ey Authority JUL 22 isa midnight on February 13, 1985; however, the fact that the water level instruments were inoperable was not recognized and they did not direct discontinuation of start-up.
In addition, during the inspection of this event, the NRC inspectors observed other problems that contribute to our concern about this 'violation.
Confusion existed regarding whether or not instrument maintenance personnel were told to investigate the level indication problem.
Since the operators left it to the instrument foreman to determine reactor vessel water level instrument operability, due to miscommunication and a lack of aggressive action on the part of the operators to resolve the discrepancies, a full hour and a half passed with no action being taken by anyone.
Also, operators and Shift Technical Advisors exhibited a lack of adequate training concerning the use of available Control Room indications for evaluation of plant, conditions with respect to reactor vessel water level.
Item B in the enclosed Notice involves your failure to take corrective action when a similar reactor vessel water level instrument problem occurred on November 20, 1984.
If effective corrective actions had been taken at that time, the event in February could have been prevented.
This violation is considered serious by the NRC in that you failed to recognize and take action when.this failure occurred, even though a similar reference leg phenomenon fs defined as a credible accident phenomenon in the Browns Ferry Emergency Procedures.
Item C in the enclosed Notice involves your failure to report this event to the NRC until approximately forty-three hours after the event occurred.
You subsequently determined the event was reportable under
CFR 50.72 and 50.73 since two low water level instrument channels, one in each Reactor Protection System trip system, were inoperable by your Technical Specification definition of operability.
In fact, it was only after the NRC residents pursued the results of your reportability determination (two days after the event) that your management subsequently filed a one-hour report.
Violations A and B, individually as well as collectively, represent a significant breakdown in your management system which resulted in the plant being operated for sustained periods of time in a significantly degraded condition with water level instrument-ation inoperability neither questioned nor recognized.
To emphasize the seriousness of these violations, I have been authorized, after consultation with the Director, Office of Inspection and Enforcement, to issue.
the enclosed Notice of Violation and Proposed'mposition of Civil Penalties in the amount of One Hundred and Fifty Thousand Dollars ($ 150,000) for the viola-tions described in the Notice.
Item A has been categorized as a Severity Level II violation in a'ccordance with the "General Statement of Policy and'Procedure for NRC Enforcement Actions,"
CFR Part 2, Appendix C
( 1985).
The base civil penalty amount for a Severity Level II violation or problem is $80,000.
However, the base civil penalty amount has been increased to $ 100,000 because of TVA's poor prior enforcement history in the area of concern.
Item B has been categorized as a Severity Level III violation and the base civil penalty of
$50,000 has been proposed.
Item C has been categorized as a Severity Level IV violation,
~1
Tennessee Valley Authority JUL 22 586 You are required to respond to the enclosed Notice and should follow the instructions specified therein when preparing your response.
In your response, appropriate reference to previous submittals is acceptable.
Your written reply to this letter an3-Me results of future inspections wi 1 1 be considered in determining whether further enforcement action is appropriate.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in NRC's Public Document Room.
The responses directed by this letter and the enclosure are not subject to the clearance procedures of the Office of Management and Budget issued under the Paperwork Reduction Act of 1980, PL 96-511.
.
Sincerely,
Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalties J.
Nelson Grace Regional Administrator cc w/encl:
J.
A. Coffey, Browns Ferry Nuclear Plant Site Oirector R.
L. Lewis, Acting Plant Manager J.
W. Anderson, Manager Office of guality Assurance K.
W. Whitt, Chief, Nuclear Safety Staff 0.
L. Williams, Jr.,
Supervisor Licensing Section R.
E.
Rogers, Project Engineer