ML18025B452
| ML18025B452 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/16/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18025B451 | List: |
| References | |
| NUDOCS 8104220971 | |
| Download: ML18025B452 (9) | |
Text
fg TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II March 16, 1981 Mr. James P. O'Reilly, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region II - Suite 3100 101 Marietta Street Atlanta, Georgia 30303
Dear Mr. O'Reilly:
This is in response to your February 19, 1981, letter to H. G. Parris, Report Nos. 50-259/80-43,
-260/80-40, and -296/80-39, concerning activities at Browns Ferry Nuclear Plant which appeared to violate NRC requirements.
Enclosed is our response to the Appendix A Notice of Violation and the Appendix. B Notice of Deviation. If you have any questions, please call Jim Domer at FTS 857-2014.
To the best of my knowledge, I declare the statements contained herein are complete and true..
Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills, Ma ger Nuclear Regulation and Safety Enclosure ax042ao'i7(
An Equal Opportunity Employer
0
ENCLOSURE
RESPONSE
TO APPENDIX A "NOTICE OF VIOLATION" REPORT NOS. 50-259/80-43,
-260/80-40,
-296/80-39 BROWNS FERRY NUCLEAR PLANT (DOCKET NOS. 50-259,
-260, -296)
VIOLATION Technical Specification 6.7.2.b requires a 30-day written report to the NRC when instrument settings are found to be less conservative than those established by the technical specifications.
Contrary to the above, Technical Specification 6.7.2.b was not met in that a refueling interlock was found inoperative during Surveillance Instruction 4.10.A.1, Refueling Interlocks, on October 4,
- 1980, and was not reported to the NRC.
This is a Severity Level V Violation (Supplement I.E.,).
1.
Admission or Denial of the Alle ed Violation TVA agrees to the violation.
On October 4,
- 1980, a defective limit switch was found on the refueling interlocks.
A surveillance instruction (SI) was being performed on three interlocks.
The switch was repaired and the surveillance successfully completed.
The refuel floor senior reactor operator (SRO) initiated a licensee reportable event determination (LRED) form per plant administrative procedures.
This form was subsequently lost between the refuel floor and the shift engineer's office..
3.
Corrective Ste s Which Have Been Taken and Results Achieved A second LRED was initiated when the NRC resident inspector identified this item.
This form was also lost.
The event was reported to NRC by BFRO 50-260/8054.
e
0 Corrective Ste s Which Will Be Taken to Avoid Further Violation Refueling floor operations personnel have been instructed to hand-car ry LRED forms to the shift engineer's office.
In addition, a tracking system has been established to ensure that plant supervisors receive assignments and submit reports within the required time.
Plant administrative procedures require that open LRED's be reviewed daily by the plant staff.
5.
Date When Full Com liance Will Be Achieved Full compliance was achieved on March 5,
- 1981, when verbal instructions were given to operations personnel on the refuel floor regarding handling of LRED's.
RESPONSE
TO APPENDIX B "NOTICE OF DEVIATION" REPORT NOS. 50-259/80-43, 50-260/80-40, 50-296/80-39 BRONNS FERRY NUCLEAR PLANT (DOCKET NOS. 50-259,
-260, -296)
DEVIATION Tennessee Valley Authority's letter dated November 5, 1980, in response to R.
C. Lewis'etter dated October 9,
- 1980, RII:RFS 259/80-34, 50-260/80-27',
and 50-296/80-28, stated that administrative instructions, in regards to fire watches being issued key cards, had been changed on November 3',
1980.
Contrary to the above, no approved change to administrative instructions had been made as of November 14, 1980, regarding fire watches being issued key cards.
1.
Admission or Denial of the Alle ed Deviation TVA agrees to the deviation.
2.
Reasons for the Deviation if Admitted The November 3, 1980, date to which TVA committed for issuing an approved change to administrative instructions, regarding fire watches being issued key cards, was missed because prior commit-ments to NRC required a much longer review and approval cycle.
The commitment to NRC required all administrative instructions that impact quality assurance (QA), or which are required by NRC Regulatory Guide 1.33, to receive a detailed review by plant QA and TVA Division of Nuclear Power QA.
The administrative instructions in question had been approved by plant management well in advance of November 3, 1980.
As a result of the new review cycle, the commitment date of November 3, 1980, could not be met.
TVA's internal draft response to Inspection Report RII:RFS 50-259/80-34,
-260/80-27,
-296/80-28 was prepared in advance of November 3,
- 1980, and stated that the administrative instructions would be changed by that date.
This draft response was finalized on November 3, 1980, without confirmation that the administrative instructions had been revised.
3.
Corrective Ste s Which Have Been Taken and Results Achieved The revised administrative instructions have been issued.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations To avoid a recurrence of this type of event, future commitment dates involving administrative instructions will reflect the additional time necessary for completion of the new review process, particularly if offsite review is required.
TVA will make additional. effort to verify that commitments are met or that revised dates are established and provided to NRC.
5.
Date When Full Com liance Will Be Achieved Full compliance was achieved on December 1,
1980, with issuance of the revised administrative instructions.