ML18033B339
| ML18033B339 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/04/1990 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9006070420 | |
| Download: ML18033B339 (8) | |
Text
ACCELERATED DISTIUBUTION DEMONSTRATlON SYSTEM l
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
SSION NBR: 9006070420 DOC. DATE: 90/06/04 NOTARIZED:
NO DOCKET FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION MEDFORD,M.O.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 900504 ltr re violations noted in Insp Repts 50-259/90-08,50-260/90-08
& 50-296/90-08.
DISTRIBUTION CODE:
IE06D COPIES RECEIVED:LTR
( ENCL g SIZE:
TITLE: Environ
& Radiological (50 DKT)-Insp Rept/Notice of Violation Respons D
05000259
/
NOTES:1 Copy each to: B.Wilson,D.M.Crutchfield,B.D.Liaw,S.Black R.Pierson, A
1 Copy each to: S.Black,D.M.Crutchfield,B.D.Liaw, 05000260 R.Pierson,B.Wilson D
1 Copy, each to:
S. Black,D.M.Crutchfield,B.D.Liaw, 05000296 R.Pierson,B.Wilson D
RECIPIENT ID CODE/NAME LA ROSS,T.
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NAL: ACRS AEOD/DSP NMSS/LLOB 5E4 NRR/DLPQ/LPEB10 NRR/DREP/PRPBll NUDOCS-ABSTRACT OGC/HDS2 RES RGN2 FILE 01 EXTERNAL: EG&G SIMPSON,F NRC PDR
~NOTES:
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5 RECIPIENT ID CODE/NAME PD AEOD/ANDERSON I R COLLINS, D RGN 2
NMSS/SGDB 4E4 NRR/DOEA/OEABll NRR/PMAS/ILRB12 OE DI G
02 RGN2 DRSS/RPB RGN4 MURRAY,B LPDR NSIC COPIES LTTR ENCL 1
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NOTE TO ALL"RIDS" RECIPIENTS PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TAL NUMBER OF COPIES REQUIRED:
LTTR 33 ENCL 32 D
D S
0 0
TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 6N 38A Lookout Place JUN 04 1990 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of Tennessee Valley Authority Docket Nos.
50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) UNITS 1, 2, AND 3 NRC INSPECTION REPORT NOS. 50-259/90-08, 50-260/90-08, AND 50-296/90-08 REPLY TO A NOTICE OF VIOLATION This letter provides TVA's reply to the Notice of Violation transmitted by letter from B. A. Wilson to 0.
D. Kinglsey, Jr.
dated May 4, 1990.
NRC cited TVA with a violations TVA admits the violation; however, TVA notes that only one of the three release pathways was not sampled.
The individual who missed the sample resulting in the Notice of Violation subsequently obtained the appropriate compensatory samples within six hours after the initiating event.
TVA considers that this event was an isolated incident caused by personnel error.
The LERs noted in the cover letter of the report are not applicable in this event and TVA provides information in this report to support this contention.
The enclosure provides background information and TVA's response to NRC concerns raised in the subject report.
All corrective actions have been completed; therefore this reply does not contain any commitments.
If you have any questions, please, telephone Patrick P. Carier at (205) 729-3570.
Very truly yours, TENNESSEE VALLEY AUTHORITY Enclosure cc:
See page 2
M. O. Medford, Vice President Nuclear Technology and Licensing
+00607
., -0~000259 0420 900604 PDR ADCiC:t~
I.>
An Equal Opportunity Employer
<a U.S Nuclear Regulatory Commi ssion Jun o4 ~oSO cc (Enclosure):
Hs.
S.
C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Haryland 20852 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637
- Athens, Alabama 35609-2000 Hr.
B. A. Wilson, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 8
101 Harietta Street,.
NW, Suite 2900 Atlanta, Georgia 30323
'e ENCLOSURE REPLY TO NOTICE OF VIOLATION'OCKETS NOS. 50-259, 50-260, 50-296/90-08 Restatement of the Violation During the Nuclear Regulatory Commission (NRC) inspection conducted on March 16 April 16,
- 1990, a violation of NRC requirements was identified.
The violation involved failure to take compensatory samples required by the Technical Specifications.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (1990),
the violation is listed below:
Technical Specification Section 3.2.D, Radioactive Liquid Effluent Monitoring Instrumentation Table 3.2.D, Note D requires that with the Raw Cooling Hater Radiation Monitor inoperable, grab samples will be collected at least once per eight hours and analyzed for radioactivity.
Contrary to the above, radiation monitor 1-RM-90-132D was inoperable and the requirements were not met on April 4,
- 1990, when two consecutive samples required by Technical Specifications 3.2.D were missed.
l.
Admission or Denial of the Violation TVA admits the violation.
2.
Reasons for the Violation if Admitted 0
The root cause of this event was personnel error.
The individual was required to take a sample from three different pathways to compensate for the unavailable sample at the radiation monitor.
One of the required pathway samples was not taken.
On April 3, 1990 at 0955 hours0.0111 days <br />0.265 hours <br />0.00158 weeks <br />3.633775e-4 months <br />, after corrective maintenance was performed on the monitor, post maintenance testing was initiated to ensure the monitor's operability.
As part of the post maintenance
- testing, an isolation valve to the raw cooling water (RCH) effluent radiation monitor was closed.
This isolation prevented the compensatory sampling from being taken at the effluent radiation monitor.
Therefore, RCH samples were required to be collected from the discharge of each reactor building closed cooling water (RBCCH) heat exchanger since the exchangers are designed in parallel upstream of the radiation monitor's sample header.
0 0'
3.
It was not until taking the required samples at 1350 hours0.0156 days <br />0.375 hours <br />0.00223 weeks <br />5.13675e-4 months <br /> on April 4, 1990 that the non-licensed utility personnel responsible for the sample discovered he had previously failed to samp'le all three flow paths as required by Surveillance Instruction O-SI-4.2.D-3B.
During the 0745 hours0.00862 days <br />0.207 hours <br />0.00123 weeks <br />2.834725e-4 months <br />
- sampling, the individual missed a sample from the spare RBCCH heat exchanger which had RCH flow.
At 1350 hours0.0156 days <br />0.375 hours <br />0.00223 weeks <br />5.13675e-4 months <br /> on April 4,
- 1990, the individual obtained the three required samples.
In fact, until the time that the monitor was returned to service, the other required samples from this system had been properly collected.
Although this event resulted from personnel error where a compensatory chemistry sample was missed, it was not a similar event to the LERs noted in the Notice of Violation cover letter.
The contributing factor to the noted LERS were:
(259/88-41)
Chemistry personnel did not adequately address compensatory sampling requirements at shift turnover, (259/88-51) an incorrect operability assessment was performed by operations personnel
- and, (296/88-06) a communication problem between Chemistry shift supervisor and Operations shift supervisor was caused by an inadequate operating instruction.
TVA has confidence that the previous corrective actions were effective for correcting the causes of those events.
This event resulted from failure to follow a procedure (O-SI-4.2.D-38) which had been upgraded in response to event described in LER 296/88-006 to reduce the probability of missed compensatory sampling.
The individual who missed the 0745 hours0.00862 days <br />0.207 hours <br />0.00123 weeks <br />2.834725e-4 months <br /> sample performed the required sampling correctly at 1350 hours0.0156 days <br />0.375 hours <br />0.00223 weeks <br />5.13675e-4 months <br /> on the same day.
In fact, the individual recognized and admitted that an adequate sample was not obtained.'his confirms that the event was caused by personnel error and that it was not affected by lack of communications or inadequate procedures as was the case for the previous events.
Therefore, TVA's previous corrective actions would not have precluded this event.
Corrective Ste s which have been Taken and Results Achieved At the time of discovery of this event, appropriate compensatory sampling of the RCN had already been obtained.
Required sampling continued until the radiation monitor was declared operable on April 5, 1990 at 1250 hours0.0145 days <br />0.347 hours <br />0.00207 weeks <br />4.75625e-4 months <br />.
4, As a result of this event, the individual involved was counseled on the importance of complying with approved plant procedures when performing assigned tasks.
This event has been discussed with appropriate Chemistry personnel in staff meetings addressing the specific event and generic issues to comply with approved procedures and the need to increase attention to details.
Additionally, a memorandum was issued to appropriate personnel to stress the importance of procedural compliance.
Corrective Ste s which will be Taken to Avoid Further Violations No further corrective actions are required to prevent recurrence.
Date when Full Com liance will be Achieved Full. compliance was achieved on April 24, 1990.