ML18025B670
| ML18025B670 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/24/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18025B669 | List: |
| References | |
| NUDOCS 8110160425 | |
| Download: ML18025B670 (14) | |
Text
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TENNESSEE VALLEYAUTHORIT~QRg Rp)
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<Il September 24, 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 R.
C. Lewis'ugust 25, 1981 letter to H. G. Parris, Report Nos. 50-259/81-22,
-260/81-22, and -296/81-22, concerning activities at the Browns Ferry Nuclear Plant which appeared to violate NRC requirements.
Enclosed is our response to Appendix A, Notice of Violation and Appendix B, Notice of Deviaton.
As discussed with Inspector P. A. Taylor on August 22,
- 1981, we are submitting our response to the Notice of Deviation within 28 days of the receipt of R.
C.
Lewis'etter, not the required 25 days. 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.
. Mills, Manager Nuclear Regulation and Safety Enclosure 0
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PDR ADQCK 05000259 I
<9, PDR An Equal Opportunity Employer
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RESPONSE
NRC INSPECTION REPORT NOS.
50-259/81-22, 50-260/81-22, AND 50-296/81-22 R.
C. LEWIS'ETTER TO H. G.
PARRIS DATED AUGUST 25.
1981 Item A - (259/81-22-02) 10 CFR 20.202 (a) requires that each licensee shall supply appropriate personnel monitoring equipment to, and shall require the use of such equipment by each individual who enters a restricted area under such circumstances that he receives, or is 'likely to receive dose. in any calendar quarter in excess of 25 percent of 18.75 REM per quarter for
- hands, forearms, feet and ankles.
Contrary to the above, the requirement that personnel be provided appropriate personnel monitoring equipment was not met in that on June 26,
- 1981, two carpenters were observed by a health physics technician to be standing on piping near a
15 REM/hr hot spot without extremity dosimeter.
This is a Severity Level IV Violation (Supplement IV D.1) and is applicable to Unit 1.
1.
Admission or Denial of the Alle ed Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted The two carpenters were performing activities outside of the area of activity described by the special work permit (SWP).
3.
Corrective Ste s Which Have Been Taken and the Results Achieved
'N a.
The carpenters were called out of the area.
b.
An extremity dose was calculated based upon existing data and assigned to each carpenter 's dose file.
Corrective Ste s Which Will Be Taken To Avoid Further Violations Belated radiological incident reports were written requiring that the carpenters be instructed to fully describe work activities when initiating a SWP and to work within the area descr ibed by the SWP.
The carpenters involved in this violation have not been involved in a repeat occurrence.
5.
Date When Full Com liance Will Be Achieved 4
The radiological incident reports described were initiated June 26, 1981 and the processing of these reports will be completed by October 15, 1981..
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Item B Technical Specification 6.3.A requires that detailed wr itten procedures shall be prepared, approved and adhered to.
Contrary to the above, the requirement that detailed written procedures be adhered to was not met in that:
1.
On June 20,
- 1981, a radwaste discharge pipe, for unit 1, measuring 7,240 disintergration per minute (DPM) smear (internally) was cut without a special work permit (SWP) as required by Radiological Control Instruction (RCI)-10, Special Work Permits.
RCI-10 requires that an SWP be issued in advance for any work assignment wher e contamination levels exceed 1,000 DPM/100 cm2.
2.
On June 26,
- 1981, a health physics technician observed two men in the vicinity of a 15 REM/hr hot spot on unit 1 Scram Discharge Header (SDH) without extremity dosimetrY.
No Radiological Incident Report (RIR) was issued by the health physics technician or his supervisor who was aware of the incident as required by RCI-1.
RCI-1 requires that violations which cause or would tend to cause a
violation of 10 CFR 20 limits shall be reported per a Radiological Incident Report.
3.
On July 9,
- 1981, an inspector observed an instrument mechanic performing Technical Instruction (TI)-60, Scram Pilot Air Header low Pressure Switches for Unit 3 without utilizing the instruction.
This is a Severity Level V Violation (Supplement I.E.).
Item B.1 (259/81-22-01) 1.
Admission or Denial of the Alle ed Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted The violation occurred because of inadequate communication between the craftsmen performing the work and the health physics technician involved.
The technician was aware. that the pipe was to be removed but failed to issue the SWP because he thought the pipe was to be removed at a later time.
3.
Corrective Ste s Which Have Been Taken and Results Achieved When plant management was made aware of the situation by the NRC inspector, proper controls were instituted.
4.
Corrective Ste s Which Will Be Taken To Avoid Further Violations The foreman involved was briefed regarding the incident and the incident was discussed in an outage foreman's meeting.
Particular
emphasis was placed on the requirement to obtain a special work permit anytime a contaminated pipe is cut.
5.
Date Full Com liance Will Be Achieved Full compliance was achieved on September 15,
- 1981, when the foreman's meeting was documented by internal TVA correspondence from the outage director to the plant compliance supervisor.
Item B.2 (259/81-22-03) 1.
Admission or Denial of the Alle ed Violation TVA admits the violation occurred as stated.
2.
Reason for the Violation if Admitted Failure to initiate the radiological incident report was an oversight on the part of the personnel involved.
3.
Corrective Ste s Which Have Been Taken and Results Achieved Belated radiological incident reports were written against the two individuals citing the incident.
4.
Corrective Ste s Which Will Be Taken To Avoid Further Violations Copies of RCI-1 which decribe.
the generation of radiological incident reports will be made more available to health physics technicians.
Technicians will be briefed to initiate and process radiological incident reports when violations occur.
5.
Date When Full Com liance Will Be Achieved The action described in paragraph 4 will be completed by September 30, 1981.
Item B.3 (296/81-22-02) 1.
Admission or Denial of the Alle ed Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted During the performance of technical instruction (TQ-60, Step 4.1.i requires that the pressure be reduced from system pressure to 50 psi on the pressure gauge.
The pressure was inadvertently dropped to zero.
Then the pressure was erroneously raised to system pressure and the switch returned to service.
The intended purpose for the step was to verify that the.isolation valve was opened to system pressure.
The instrument mechanic involved stated that the
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reasons for the error were the extremely hot working area and that he became nervous and frustrated and misinterpreted the purpose to pressurize to system pressure to prevent a negative spike which would have scrammed the unit.
3.
Corrective Ste s Mhich Have Been Take'n and Results Achieved The isolation valves were reinspected to be open to the air system and the gauges observed for response.
The findings showed the isolation valves were indeed opened as required.
4.
Corrective Steps Which Mill Be Taken To Avoid Further Violations All instrumentation personnel were cautioned on July 21,
- 1981, and again on September 1,
1981, to adhere strictly to the written procedure (step by step).
5.
Date When Full Com liance Mill Be Achieved Full compliance was achieved on July 21,
- 1981, when instrumentation personnel were cautioned in adherence to procedures.
Item C (260 296/81-22-01)
Technical Specification 4.7.G.1.a requires that at least once per month, each solenoid operated air/nitrogen valve in the Containment Atmosphere Dilution System (CAD) shall be cycled through at least one complete cycle of full travel.
Contrary to the above, the cycling of each solenoid operated air/nitrogen valves at least once per month was not met in that valves FCV-84-16 and 5, which are common to Units 1, 2, and 3, were not cycled between March 1981 and July 13, 1981.
This is a Severity Level V Violation (Supplement I.E.) and is applicable to Units 2 and 3.
1.
Admission or Denial of the Alle ed Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted Containment atmosphere dilution system (CAD) valves FCV-84-5 and
~ FCV-84-16 were not cycled once each month per Technical Specification 4.7.G.1.a.
Failure to cycle the valves each month was due to a procedure deficiency, in that operability was to be checked by the unit 1 operator during the performance of unit 1 surveillance instruction (SI).
Unit 1 was in a refueling outage and unit 1
SI-4.7.G.1.a had been dropped until startup.
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3.
Corrective Ste s Which Have Been Taken and Results Achieved Upon discovery of the incident, the common CAD system valves FCV 5 and FCY-84-16 were immediately cycled and proved operable on July 17, 1981.
4.
Corrective Ste s Which Will Be Taken To Avoid Further Violations SI-4.7.G. 1.a has been revised to require the unit 2 operator to check CAD valve operability of common valves when unit 1 is shut down+
5.
Date When Full Com liance Will Be Achieved SI-4.7.G.1.a was revised July 21, 1981.
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APPENDIX B NOTICE OF DEVIATION (260/81-22-02 and 296/81-22-03)
Based on the NRC inspection conducted on June 26 through July 26, 1981 certain of your activities appear to deviate from your commitments to the Commission as indicated below:
The Browns Ferry Final Safety Analysis Reports (FSAR)
Section 5.2.6.2 states that the Containment Atmosphere Dilution (CAD) system nitrogen storage tanks are to be maintained at a minimum pressure of 100 psig.
Contrary to the above, on June 13, 1981 the inspector noted that the pressure in the A and B nitrogen storage tanks were 85 psig and 60 psig respectively.
Reasons for the Deviation As stated in the report, the CAD system nitrogen tank pressure for A and B tanks was not being maintained at a minimum pressure of 100 psig.
There were no requirments in procedures to maintain a 100-psig minimum pressur e.
This FSAR requirement was evidently overlooked in preparing plant procedures.
Corrective Actions That Have Been or Will Be Taken Upon discovery of the deviation, immediate corrective maintenance was initiated and the pressure regulators adjusted on A and B nitrogen tanks to maintain greater than 100-psig tank pressure.
a Corrective Actions Which Will Be Taken To Avoid Further Deviations SI-2 has been revised to require a check and log entry of the tank pressure once each day.
Signs have been placed at the nitrogen tank station to ensure the pressure is at least 100 psig after each filling operation.
Date Corrective Actions Were Com leted SI-2 was revised July 20, 1981.
Signs were placed at the storage tanks July 17, 1981.
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