ML18024B284

Forwards Responses to NRC 800104 Ltr Forwarding Notice of Violation,Notice of Imposition of Civil Penalties & Order Modifying License.Outlines Corrective Actions Taken.Forwards Civil Penalty Fee

ML18024B284
Person / Time
Site:	Browns Ferry
Issue date:	01/10/1980
From:	Parris H TENNESSEE VALLEY AUTHORITY
To:	Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8001290519
Download: ML18024B284 (12)

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f TENNESSEE VALLEY AUTHORlTY KNOXVILLE.TENNESSEE 37902 January 10, 1980 Mr. Victor Stello, Jr.

Director, Office of Inspection and Enforcement Nuclear Regulatory Commission Washington, DC 20555 Re: Docket Nos. 50-259, -260, -296

Dear Hr. Stello:

This is in response to your January 4,'1980, letter enclosing a Notice of Violation, Notice of Proposed Impo'sition of Civil Penalties, and an Order Modifying License Effective Immediately, These documents relate to the events at Browns Perry Nuclear Plant unit 3 on December 6-9, 1979.

TVA is fully committed to the safe operation of its nuclear facilities.

An inherent part of this committal is TVA's support of the NRC inspection and enforcement program. We believe that a strong and effective program is essential to safe operation of nuclear reactors. It is the policy of the TVA Board to cooperate with NRC in this effort as fully as possible.

The events at Browns Ferry on December 6-9 did not result in any immediate safety hazard, but rather involved differing interpretations of technical specifications and reporting requirements, In these matters we of neces-sity must defer to NRC. Accordingly, TVA, does not desire to contest the matters set forth in the Notice of Violation.

The TVA Board has directed the TVA staff to:

1. Report, any and all abnormal occurrences to NRC and to TVA's Nuclear Safety Review Staff (who will keep the Board informed) at the time they occur, whether or not they are technically "reportable" under NRC regula-tions. Staff should in the future err on the side of reporting in case of doubt,

2. Undertake an jntensive review of the technical specifications at Browns Perry, in cooperation with NRC staff, to resolve any ambiguities that exist in light of the more stringent safety policies of,the TVA Board and the NRC subsequent to Three, Mile Island, Appendix A to this letter sets out the corrective actions pursuant to paragraphs Q) through (4) of the Order, Appendix.B is TVA's response to the Notice of Violation, and points out the understanding which TVA had of certain technical specifications which differed from that of NRC.

0 NRC<s uodetstandint of 'the tequitements has been adopted by TVA.

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'0 An Equal Opportunity Employer

Mr. Victor Stello, Jr. January 10, 1980 Also enclosed is a check for S29,000 in payment of the civil penalties.

If additional information is needed to resolve this matter, please let me know.

Very truly yours, TERKSSEE VALLEY AUTHORITY Hugh . Parris Manager of Power Enclosures

APPENDIX A TENNESSEE VALLEY AUTHORITY RESPONSE TO NRC ORDER MODIFYING LICENSE EFFECTIVE &MEDIATELY BROllÃS FERRY NUCLEAR PLANT Docket No. 50-239 License No. DRP-68 Response to 5 III(l) of the Order TVA has developed written, detailed procedures requiring independent verification to ensure that this par-ticular maintenance activity is performed correctly. This was completed on Decenber 18, 1979.

Response to 5 III(2) of the Order TVA has reviewed all'anagement and administrative controls governing maintenance activities to assure that they do not permit maintenance or other activities to violate limiting condi-ions for operation. As a result of this review, TVA has added the prinary containment equipment hatches to the startup procedure checklist.

The startup checklist will require verification that the hatches have not V

been opened or-loosened. These procedures will be completed by January 10, 1980.

Response to 5 III(3) of the Order TVA has developed and will use in the future written detailed maintenance procedures in removing and replacing all containment penetration closures. This procedure was issued on December 18, 1979.

Response to 5 III(4) 'of the Order TVA has made a detailed review of reporting procedures to assure full compliance with all reporting require-ments required by the Browns Perry technical specifications. Revision of these procedures will require notification on a daily basis to NRC of all potential reportable occurrences and will be issued by January ll, 1980.

APPENDIX B TENNESSEE VALLEY AUTHORITY RESPONSE TO NRC NOTICE OF VIOLATION DATED JAIKARY 4, 1980 BROGANS FERRY NUCLEAR PLANT Docket No. 50-259 License No. DRP-68 This is in response to the Notice of Violation included as Appendix A in the letter dated January 4, 1980, from the Director, Office of Inspec-tion and Enforcement, Nuclear Regulatory Commission, concerning events at Browns Ferry Nuclear Plant unit 3.

It is important that the NRC inspection and enforcement program be strong and effective, and that licensees cooperate with the program as fully as possible, It is the policy of the TVA Board of Directors that TVA give this cooperation by fully meeting NRC's regulatory requirements.

Accordingly, TVA'oes not desire to contest the matters set forth in the Notice, and is forwarding a check'n the amount of $ 29,000 in payment of the civil penalties imposed.

One generic matter which this Notice points out is that from time to time there will likely be differing interpretations of technical specifica-tions and regulatory requirements between NRC and a licensee, In our view, that is the case in these violations. As pointed out below, TVA staff had an underatanding of the requirements set out in the Notice which differed from the NRC's understanding. As indicated, TVA will meet NRC's understanding of the various requirements.

Response to 5 A of the Notice . It was TVAage to demonstrate an acceptable leakage. The NRC has applied i.tern 3.7.A..2 of the technical specifications as not permitting any remedial act on, that primary containment integrity must be maintained at all times, and that the reactor should have been shut down upon discovery of the prinary containzent leak.

TVA has taken iunediate steps to ensure that NRC's application of this requirenent is implemented, Procedures will be revised to require that ni.trogen consumption be monitored on a shift basis. Should nitrogen consmzption exceed a predetermined value, an immediate investigation w IZ be conducted to determine the cause. If the cause of excessive nitrogen consumption has not been determined wi.thin six hours, the reactor shall be in at least hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in cold shutdown within the following 24 hours. If the investigation indicates that primary containment integrity h

does not exist or, if at any time, containnent integrity is not maintained, primary containment integrity

shall be restored within 1 hour or the reactor shall be in at least hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in cold shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. These procedures will be revised and full compliance achieved by January 10, 1980.

Response to 5 C of the Notice It was TVA's prior understanding that item 4.7.A.2.h(l) and (2) of the technical specifications, concerning primary containment leakage, permitted continued operation and repairs under these circumstances. Since this was classified as a mode of operation under a limited condition of operation, TVA's initial interpretation was that the event fell within item 6,7.2.b(2) of the technical specifi-cations and was reportable within thirty days. When calculations showed the leakage exceeded the allowable limits, a prompt report was made to NRC.

The NRC's application of item 3.7.A,2 of the technical specifications does not permit remedial action prior to shutdown. Accordingly, NRC has now ruled that TVA upon discovery of the leak should have made a prompt assessment of the magnitude of the leak, taken the appropriate action, and reported to NRC within 24 hours.

As discussed in TVA's response to section B of the No'tice, immediate steps to ensure that NRC's application of this requirement will be imple-mented. In conjunction with this change, plant reporting procedures will ensure full compliance with item 6.7.2,a and 6,7,2.b of the techni-cal specifications by January 10, 1980,

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