ML19326E199

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Responds to NRC Re Violations Noted in Insp Repts 50-259/80-20,50-260/80-15 & 50-296/80-16.Corrective Actions:Valve Calibr Orientation Corrected.Justifies Decision Re Nonreporting of Diesel Generator Failure
ML19326E199
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 06/16/1980
From: Mills L
TENNESSEE VALLEY AUTHORITY
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19326E197 List:
References
NUDOCS 8007280468
Download: ML19326E199 (4)


Text

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TENNECEE VALLEY AUTHORITY c

CH ATTANOOG A. TENNESSEE 3750i. 'm 0 R E 3. ' '-

400 Chestnut Street Tower 11. NT^> -.

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.0 JWilS A9: 3I June 16, 1980 Mr. James P. O'Reilly, Director Office of Inspection and Lnforcement U.S. Nuclear Regulatory Commission Region II - Suite 3100 101 Marietta Street Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Enclosed is out response to R. C. Lewis' May 20, 1980, letter, RII:JWC 50-259/80-20, 50-260/80-15, and 50-296/80-16, concerning activities at Browns Ferry Nuclear Plant which appeared to be in noncompliance with NRC requirements.

We have reviewed the above inspection report and find no proprietary information in it.

If you have any questions, please call Jim Domer at FTS 857-2014.

Very truly yours, TENNESSEE VALLEY AUTHORITY

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\\J / d L. M. Mills, Ma ager Nuclear Regulation and Safety Enclosure 6

4 JFICIAI, COPY An Equal Opportunit h [y Employer 8007280

ENCLOSURE RESPONSE TO R. C. LEWIS' LETTER DATED MAY 20, 1980,

REFERENCE:

RII:JWC 50-259/80-20, 50-260/80-15, 50-296/80-16 INFRACTION - ITEM A As required by Item 6.3.A.1 of the facility technical specification, detailed written procedures, including checkoff lists, shall be prepared, approved and adhered to for surveillance and testing requirements.

Contrary to_the above, on April 22, 1980, Surveillance Instruction 4.1.A-7, Reactor Protection System Reactor Water Level, was not adhered to during its performance on Unit 2 in that system alignment was not followed.

This is an infraction which is applicable to Unit 2.

RESPONSE

Orientation of the calibration valves was the major cause for the infraction reported.

They are installed such that the handles are not at the front of the panel but rotated up to 180 degrees from the panel front. The instrument mechanic (IM) inadvertently turned the valve in the wrong direction due to the handle orientation. When the unexpected half scram occurred, he reasoned that the instruction may'have been written as viewed from the rear of the panel. This of course was not the case and the main turbines tripped due to the false high reactor water level signal.

Corrective Action Taken And Results Achieved The calibration valve orientation will be corrected during the next refueling outage. Each IM has been cautioned not to deviate from the written procedure.

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l Corrective Steps Taken To Avoid Further Noncompliance l

A mark-up of the instrument and the valves involved has been assembled.

Each LH will be required to perform the valving out and return to-service I

according to SI 4.1.A-7.

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s INFRACTION - ITEM A (continued)

Date Full Compliance Achieved This item was discussed with all IM's on April 29, 1980, and full compliance was achieved on April 29, 1980.

INFRACTION - ITEM B As required by 10 CFR 50.72(a)(7), the licensee shall notify the NRC Operations Center as soon as possible and in all cases within one hour by telephone of the occurrence of significant events which are listed.

Item (7) on the list requires reporting of events resulting in manual or automatic actuation of Engineered Safety Features, including Reactor Protection System.

Contrary to the above, a prompt report was not made to the NRC Operations Center following the automatic actuation of the "B"

Diesel Generator at 1:00 p.m. on April 23, 1980.

This is an infraction which is application to Units 1 and 2.

RESPONSE

Corrective Steps Taken and Results Achieved Because of the nature of this event, no corrective action was necessary.

Corrective Steps Which Will Be Taken To Avoid Further Noncompliance We ask the findings of noncompliance on this particular matter be reconsidered in light of the event.

It is significant to note that had this shutdown board been out of service because of an electrical fault or had been removed from service for maintenance it would not have required a report under 10 CFR Part 50.72.

Therefore, it was our decision not to report. Our reporting guidelines have been based on reporting those events that could have significance, such as system level actuations initiated by protective system. In this, articular case there was not a voltage problem at the plant level.

It existed on this particular board because of unusual loading conditions.

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INFRACTION - ITEM B (continued.

i Taken literally, 10 CFR Part 50.72 would require that we notify the NRC at any time any engineered safety feature is started for surveillance j

or other routine tests. We would also be required to notify the NRC whenever any part of the reactor protection system is actuated due to periodic surveillance or routine testing. We do not believe this is the intent of the regulation.

Date When Full Compliance Will Be Achieved l

We have reviewed our reporting requirements and consider our actions on April 23, 1980, to have been in full compliance with 10 CFR Part 50.72.

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