ML18025B607
| ML18025B607 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/07/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18025B609 | List: |
| References | |
| NUDOCS 8109010499 | |
| Download: ML18025B607 (10) | |
Text
I."~~'Ii~CT~ENNESSEE VALLEYAUTHORITY
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CHATTANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II 9t I.:,.'," I3
~i~. I'ugust 7, 1981 Mr. James P. O'Reilly, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region II Suite 3100 101 Marietta Str eet Atlanta, Georgia 30303
Dear Mr. O'Reilly:
This is in response to R.
C. Lewis'uly 8, 1981 let;ter to H. G. Parris, Report Nos. 50-259/81-14, -260/81-14'nd
-296/81-14, concerning activities at the Browns Ferry Nuclear Plant which appeared to violate NRC requirements.
Enclosed is our response to Appendix A, Notice of Violation. 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 M. Mills, M ager Nuclear Regulation and Safety Enclosure 810111010499 810818)
PDR ADOCK 05000259 8
PDR An Equal Opportunity Employer
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ENCLOSURE
RESPONSE
TO R.
C. LEWIS'ETTER DATED JULY 8, 1981 TO H. G.
PARRIS XNSPECTION REPORT NOS.
50-259/8l-l4, 50-260/8l-l4, AND 50-296/8l-l4 Violation A Technical Specification 3.5.E.l requires that the high pressure coolant injection system shall be operable whenever there is irradiated fuel in the reactor vessel and the reactor vessel pressure is greater than l22 psig.
Operating Instruction 57 requires the HPCX injection valve (73-44) to be open for the HPCX system to be considered operable when a unit battery is out of service.
Contrary to the above, the HPCI system was inoperable in that the HPCI injection valve (73-44) was not opened when a unit battery was removed from service at l:l6 p.m.
on Hay 5, l98l, nor was the system declared inoperable until 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> after unit battery was removed from service for a load test.
This violation continued for about 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> after our inspector informed plant supervision of the violation.
This is a Severity Level IV Violation (Supplement I.D.3) applicable to unit 3.
l.
Admission or Denial of the ~Alla ed Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted Due to a leaking downstream check valve causing excessive suction pressure on the HPCX pump, the unit 3 HPCI discharge valve (FCV 73-
- 44) could not be opened as required by SI 4.9.A.2.c.
Operations personnel were not aware of Step l0 of the GE design criteria on figures 8.6-4b and 8.6-4c of the FSAR.
The requirements of operational instruction (OI) 57 to declare the HPCI system inoperable were inadequate because there was no control in effect to flag the use of this procedure during the performance of SI 4.9.A.2.c or during the sequence of events associated with the HPCI pump suction pressure problems.
3.
Corrective
~Ste s Which Have Been Taken and Results Achieved When supervisors were made aware of the requirements in OI-57, the HPCI system was declared inoperable and appropriate surveillance tests were performed.
The HPCI system remained inoperable until 4.9.A.2.c was completed.
Corrective
~Ste s Which Will Be Taken to Avoid Further Violations A.
SI 4.9.A.2.c has been revised to state the reason for HPCI valve FCV 73-44 abnormal, lineup and to add a prerequisite signoff to ensure that all prerequisites have been met.
B.
This event will be covered in licensed operator retraining along with the findings of the inspection report.
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5.
Date When Full Com liance Will Be Achieved A.
SI 4.9.A.2.c has been revised and was PORC approved on July 2l, 1981.
B.
Retraining on the event will be complete by January l, 1982.
Violation B Technical Specification 3.LL.A.L.b requires that the high pressure fire protection system shall have automatic initiation logic operable.
Contrary to the above, the requirement for automatic initiation logic to be operable was not met in that on May 1, 198L it was deter mined by the licensee that the automatic start feature for the fire pumps was inoperable and had been in this condition since sometime after April l7, 198l.
This condition was caused by leads being lifted in the automatic start circuit during plant modifications.
This is a Severity Level V Violation (Supplement I.E.).
l.
Admission or Denial of the ~Axle ed Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted A modification in the fire protection logic system panel was being performed when leads were apparently inadvertently lifted.
Lifting these leads removed power for the automatic start logic for the fire protection system.
The engineer in charge of the job had previously taped the terminal block in question and instructed the craftsmen not to work behind the tape.
We have concluded that the craftsmen involved were responsible for the violation.
3.
Corrective
~Ste s Nhich Have Been Taken and Results Achieved The leads that were Lifted for the automatic start feature of the fire pumps were reconnected immediately upon discovery and the auto start feature of the fire pumps was restored.
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Corrective
~Ste s Mhich Hill Be Taken to Avoid Further Violations The craft foremen and general foremen have been made aware of the necessity to follow verbal instruction from the cognizant engineers an to follow the workplan.
v 5.
Date When FulL Compliance Will Be Achieved We were in full compliance on May 2, l98l when discussions were held as described in item
>) above.
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Violation C Technical Specification 6.3.A.6 requires detailed written procedures be
- prepared, approved and adhered to for surveillance and operations of systems and components involving nuclear safety.
le Contrary to the above, written procedures were not adhered to in that the HPCI discharge valve (73-44) was not opened for unit 3 as requir ed by the prerequisite section of Surveillance Instruction 4.9.A.2.c during a battery discharge test on May 5-6, l98l.
2.
Contrary to the above, a written procedure, which specified switch position (Operating Instruction 3l) was not followed for the operation of the control room emergency pressurization unit (CREU) in that on May 20, l98l at 8:45 a.m.,
the "8" CREU unit would not start auto-maticaLLy on an accident signal because of an improper switch lineup.
This is a Severity Level V Violation (Supplement I.E.).
Violation C.1 l.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted The senior reactor operator (SRO) assigned to perform SI 4.9.A.2.c misinterpreted the requirements to open HPCI discharge valve FCV 73-44 to apply only to the unit 2 HPCI which was the unit battery under test After this misinterpretation of the procedure, further action was not considered by the operators.
3.
Corrective
~Ste s ilhich Have Been Taken and Results Achieved A.
The HPCI system was declared inoperable on May 6, L98l. It was not possible to open FCV 73-44 due to the probability that the pump would be damaged by the high suction pressure.
(See response to Violation A.)
B.
The event was discussed with the SRO assigned to SI 4.9.A.2.c and the SRO was given a verbal reprimand.
4.
Corrective
~Ste s 'i&ion 'iiiliBe Taken to Avoid Fur ther Violations A.
SI 4.9.A.2.c has been revised to clearly state that the requirement to open FCV 73-44 applies to all units.
B.
This event and the findings of the inspection report will be covered in Licensed operator retraining.
A.
SI 4.9.A.2.c has been revised and was PORC approved on July 2l, L98l.
B.
Licensed operator retraining will be completed by January l, 1982.
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Violation C.2 1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted Determination has not been made as to what events Lead to the specific violation.
The most probable cause was the switches being realigned in the incorrect position following testing of the control room emergency pressurization unit system.
Surveillance instruction 4.7.E.6 for the control room emergency pressurization system operabil,ity was found to be inadequate to ensure proper switch alignment following completion of the operability test.
3.
Corrective
~Ste s Mhich Have Been Taken and Results Achieved The "B" control room emergency pressurization unit switches were immediately realigned in the proper position and surveillance tests were performed on the "A" and "B" control room emergency pressurization units to prove operability.
4.
Corrective
~Ste s Mhich HiAA Be Taken to Avoid Further Violations SI 4.7.E.6 for testing the control room emergency pressurization systems has been revised to ensure proper lineup of control switches upon completion of testing.
- SI 4.7.E. 6 has been revised and was. PORC approved on July l4, l98L.
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