ML18029A913
| ML18029A913 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/03/1985 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8510180069 | |
| Download: ML18029A913 (9) | |
Text
TENNESSEE VALLEYAUTHORITY CHATVANOOGA. TENNESSEE 37401 V g /
400 Chestnut Street Topi"pI October 3, 19859 0
U.S. Nuclear Regulatory Commission Region II ATTN:
Dr. J, Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Dear Dr. Grace:
BROWNS FERRY PLANT UNITS 1 2,
AND 3 NRC-OIE REGION II INSPECTION REPORT 50-259/ 5-39 50-260/85-39, 50-296/85-39
RESPONSE
TO VIOLATION Enclosed is our response to R.
D. Walker's September 4,
1985 letter to H.
G. Parris transmitting IE Inspection Report Nos. 50-259/85-39, 50-260/85-39, and 50-296/85-39 for our Browns Ferry Nuclear Plant which cited TVA with one Severity Level IV Violation and one Deviation.
If you have any questions, please get in touch with R.
E. Alsup at FTS 858-2725.
To the best of my knowledge, I declare the statements contained herein are Very truly yours, TENNESSEE VALLEY AUTHORITY J.
A. Domer, Chief Nuclear Licensing Branch Enclosure cc; Mr. James Taylor, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 8510180069 851003 PDR ADOCK 05000259 8
PDR An Equal Opportunity Employer 1
-/
F W
ll
RESPONSE
NRC INSPB(ZION REPORT NOS.
50-259/ &5-39, 50-260/ &5-39, AND 50-296/ &5-39 ROGER D. WALKER'S LETTER TO H, G.
PARRIS DATED SEPZEMBER 4, 19&5 Item 1 Technical Spocif ication 6.3.A.1 requires that dotailed written procoduros, including applicablo checkoff lists, shall bo proparod,
- approved, and adhexod to for normal startup, operation and shutdown of all systems and canpoaonts involving nuclear safoty of tho facility.
Coatraxy to the above, this roquirement was aot met for the following two oxsmples
~Exam le la Operating Instruction OI-65, Standby Gas Treatment (SBGT)
Systom Operation did not address that tho charcoal bod heaters had to be manually reset af ter the SBGT system was socurod.
Although Liconsoo Event Report 259/&5-29 implios this was not previously Known, Final Safety Analysis Roport Figure 5.3-9 note six describes tho manual reset, l.
Admission or Denial of the ~Alla ed Violation TVA admits tho violation.
2 ~
Reasons For the Violation Cognizant plant personnel were not awaro of tho aocossity to manually reset the hoators oven though Final Safety Analysis Report (FSAR),
Figuro 5.3-9, Note 6, describes the Function.
Cogaizant personnel were made aware of the necessity to manually xeset tho heator control switch after a TVA review of tho SBGT control cix'cuitry discoverod the requir ement.
3.
C recotriv
~Stees Which Have Been Taken and Results Achieved The SBGT control board was tagged with a caution ordor to instruct the operator to rose t tho hoater logio af ter socuring the SBGT systom.
Aftox furthor investigation, an ongiaooring evaluation concluded that Technical Specification 4.7.B.2.d, which requires the operation of each SBGT train for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> each month with the associated relative humidity heaters operating, obviates the aood for thoso chaxcoal heaters.
Tho hoaters have subsequently been taggod out and a
dosign chango has been initiated to permanontly remove theso heaters fxom tho SBGT system design.
Page 2
~Bran le la (continned) 4.
Corrective ~Bte s Which Will Be Taken to Avoid Bnrther Violations Long-term corrective acti. on is committed to in Licensee Event Report (LIE) 259/85029 Rl and will consist of the permanent removal of the heaters and revising the PSAR to reflect the new conf iguration.
Revise FSAR in annual update (July 1986) and rcmove heaters in accordance with commitment in LER.
Page 3
~Bran le lh On July 30, 1985, Surveillance Instruction SI 4.7,B-1, SBGT Operabil ity Test was being used which did not contain a change dated July 7, 1985, that required the charcoal bed heaters to be reset af ter system shutdown.
A review of completed SI 4.7.B-1 procedures since the change was implemented found three out of 10 did not contain the change, Operations personnel are instructed by Operations Section Instruction Letter SIL-40 to compare pago-by-pago procedures used against a controlled copy of the procedures to insure revisions are incorporated.
l.
Adnission or Denial of the ~Alle ad Violation TVA admits the violation.
2 ~
Reasons For the Violation SI 4.7.B-l, SBGT Operability Test, was being ran for an instrument check.
The change dated July 7, 1985, did not require a permanent procedure change therefoxe, it should not have been included with any data sheets.
S.
Corrective
~Ste s Which Have Been Tahoe and Results Achieved The change dated July 7,
- 1985, has been removed and will not be included with any future SI 4.7
~ B-1 data sheets.
OSIL-40 has been revised to include the requirement that the back of a surveillance coversheet be stamped and signed, verifying all pages in the data sheet package have been compared to official control room instructions.
4.
Corrective ~Ste s Which Will Be Taten"to Avoid Farther Violations Actions descxibed in step 3 should be sufficient to prevent future recurrence s.
Full'ompliance has been achieved.
Page 4
Devia tion Final Saf ety Analy sis Report (FSAR) section 5.3.3.7, Standby Gas Treatment (SBGT)
- System, states that the charcoal bed tempexature is thermostatically controlled with high and Iow temperature alarms in the Control Room.
Contrary to the above, no low temperature alarm existed for the charcoal bed temperature.
No other means was established to insure the SBGT heaters were operable.
When the operability of the heaters was questioned by the inspector, train B and train C were found not to be operating properly.
I.
Corrective ~Ste s Which Rave Been Taken and Resnlts Achieved As stated in LER 259/85029 Rl, the FSAR was in exror on the existence of low-tempexature alarms.
- Also, a design evaluation performed by TVA concluded that Surveillance Requixement 4.7.B.2.d, which requires the operation of each SBGT train for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> a month with the relative humidity heaters operating, obviates the need to keep the charcoal bed heaters.
As a result, a low temperature alaxm is also not required since the charcoal bed heater operability is no longer r equire d.
2.
Corrective ~Ste s Which Will Be Taken to Avoid Farther Violations
- FSAR, Section 5.3.3.7, Standby Gas Treatment System, will be revised to reflect the actual configuration of the SBGT trains.
3.
Date When Full Com liance Will Be Achieved Revise FSAR in annual update (July 1986).