ML19351E882

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Responds to NRC Re Violations Noted in IE Insp Repts 50-259/80-28,50-260/80-21 & 50-296/80-22.Disputes Finding of Noncompliance
ML19351E882
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 09/04/1980
From: Mills L
TENNESSEE VALLEY AUTHORITY
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19351E866 List:
References
NUDOCS 8012190492
Download: ML19351E882 (3)


Text

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P00 C"antrut St-aat Tmrer II

'J Septnmber 4, 1000

'!. James P. O'Reilly, Director Office of Inspection and Enforcenant U.S. Nuclaar 9agulatory Conmission Recice II - Suite 3100 101 "s"letta Street Atlanta, Georeia '0?07 D a m. " vr. O'Raillv:

Enclosad is cua resconse to '>. C. L*'ei s ' August 19, 19PC, ktter, RII:RFS 90-259/80-29, -260/80-21, ard -2##/90-22, coreceninc activities at Brot:nr Farry 'uclear Plant which appaared to be ir noncompliance with 'IRC requirements.

'le have revie'4a1 the above inspection report ant' find no orcprieta"v info mation in it.

If you have any cuestions, nlaase call Ji-M.nr at FTS B57 0014 Very trul" veurs, T "ESSEE VALLEY AU7?ORITY ri s

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i ENCLOSURE RESP 0MSE TO R. C. LEWIS' LETTER DATED AUGUST 15, 1080, TO H. G. PARRIS BROWS FERPY MUCLEAR PLANT (RII:RFS 50-p50/80-??, -260/80-21, -266/80-22)

Appendix A of the inspection letter identified activities which were apparently in noncompliance with NRC requirements.

The following are those items and our response.

Infraction As required by 10 CFR 50 Appendix B and implemented by Tennessee Valley Authority Nuclear - Operational Quality Assurance Manual Section 2.1 Part II, upon completion of maintenance on any item of the CSSC list and before release for service, appropriate testing shall be performed to verify operational acceptability.

Contrary to the above, on June 23, 1980, the control valve #2 i

pressure sensor, which sends a sign't to the Reactor Protection System to indicate turbine control valve fast closure, had maintenance performed on it and was returned-to service without testing of the Reactor Protection System to verify proper operation of the repaired pressure switch.

Response

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l Cortective Steps Taken and Results Achieved i

The subject pressure switch, located in the Reactor Protection System, i

is automatically bypassed and not in service below 30-percent power.

(Referenec:

Browns Ferry Technical Specification 3.1-A, Table 3.1.A,

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"Operabilit'/ of Turbine Control Valve Loss of Oil Pressure Trip Function at Power Levels > 30 percent.") Bypass of this scram function below 30-percent power is provided by a pressure s itch that monitors turbine

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first-stage pressure.

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5 It is our position that the intent of the OQAM ar d the technical specification l

was net.

Testing of the subject pressure switch 1s normally performed above 30-percent power by procedure S.I. 4.1. A.12.

Testing of the subject reactor protection system pressure switch was accomplished as soon as l

l possible after the 30-percent automatic bypass interlock was cleared.

i C_orrective Steps Taken to Avoid Further Noncompliance 1

4 Events related to the failure of the subject pressure switch (PS-47-144) have been reported under Licensee Event Report 50-259/8050. Additionally, the TVA Division of Nuclear Power Quality Assurance Staff has investigated 4

the incident and prepared a report including recommendations to prevent recurrence.

These recommendations are being studied for future corrective action. However, this independentinvestigation concurred with the position stated regarding the testing of the switch.

Date Fulf Compliance Achieved t

It is TVA's opinion that we were not in noncompliance with 10 CFR Part 50 l

or the TVA OQAM.

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