ML20039A202

Responds to NRC 811030 Ltr Re Violations & Deviation Noted in IE Insp Repts 50-259/81-28,50-260/81-28 & 50-296/81-28. Corrective Actions:Mechanical Maint Instruction Revised & Commitment Tracking Sys & Documentation Program Developed

ML20039A202
Person / Time
Site:	Browns Ferry
Issue date:	11/30/1981
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20039A199	List: ML20039A202 ML20039A206
References
NUDOCS 8112160352
Download: ML20039A202 (3)

Text

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1 ENCLOSURE RESPONSE TO NOTICE OF DEVIATION APPENDIX B R. C. LEWIS' LETTER TO H. G. PARRIS DATED OCTOBER 30, 1981 REPORT NOS. 50-259/81-28, -260/81-28, -296/81-28

' APPENDIX B '

Item A - (259/81-28-07, 260/81-28-04, 296/81-28-04)

The Browns Ferry FSAR, volume 7, Q2.6-5 requires that at specified intervals the residual heat removal service water (RHRSW) pump compartments will be flood tested to demonstrate each RHRSW pump operability during the test. Additionally, it is specified that the test will require filling each compartment to a depth of 18 inches of water.

Contrary to the above, a review of records and observation of Mechanical Maintenance Instruction 19 indicates that only eight of the twelve RHRSW ,

pumps are routinely scheduled for the flood test. RHRSW pumps A3, B3, C3,

and D3 are not scheduled for testing and the RHRSW compartments flood test is only conducted at the 6 inch water level.

1. Corrective Steps Which Have Been or Will Be Taken RHRSW pumps A3, B3, C3, and D3 have always been tested with the original RHRSW pumps during the performance of MMI-19 but were not documented due to an outdated data sheet. MMI-19 was revised and approved by PORC October 6, 1981, to include A3, B3, C3, and D3 pumps on the data sheets.

2. Corrective Actions Which Will Be Taken To Avoid Further Deviations Corrected MMI-19 data sheets will be used on future performance of the maintenance instruction.

As part of a general FSAR update, a FSAR revision has been proposed to specify 6 inches instead of the present 18-inch fill requirement. We believe that the test performed at the 6-inch level is sufficient to demonstrate operability of the affected equipment; however, wa are reevaluating the test method as prescribed by MMI-19 to ensure that the intentions of the original FSAR commitment are being met.

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, l 3 Date Corrective Actions Were or Will Be Completed Reevaluation of the flood test method will be completed by January 22, 1982. The FSAR update will be completed by July 22, 1982.

Item B - (259/81-28-01, 260/81-28-01, 296/81-28-01) -

TVA's response to items A and C in the Notice of Violation of Inspection Report 50-259/81-03, 50-260/81-03, and 50-296/81-03 stated as part of the corrective action that an Outage Safety Awareness Bulletin was issued to inform personnel on the proper use of door airlocks and on the requirements in the transportation of material from the plant to other areas.

Contrary to the above, the licensee had not issued the Outage Safety Awareness Bulletin. An Outage Safety Awareness Bulletin was issued on September 14, 1981, which is approximately five months after the licensee responded to the items.

1 Corrective Steps Which Have Been or Will Be Taken A field services safety awareness bulletin was issued September 14, 1981. The bulletin was not issued as stated in the subject inspection report because of an oversight by persons responsible for implementing this action.

2. Corrective Actions Which Will Be Taken To Avoid Further Deviations The Browns Ferry Compliance Staff has fully implemented a commitment tracking system and a documentation program that now provides positive verification of commitment action taken. Field services will develop a procedure for followup, documenting corrective actions taken, and supplying notification to the Browns Ferry Compliance Staff that required actions are complete.

3 Date Corrective Actions Were or Will Be Completed A procedure will be pqred and issued by December 18, 1981.

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. TENNESSEE VALLEY. AUTHORITY,[5 g CH ATTANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II 31 DE r. I P2 2h November 27, 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' October 30, 1981 letter to H. G. Parris, Report Nos. 50-259/81-28, -260/81-28, and -296/81-28, concerning activities at the Browns Ferry Nuclear Plant which appeared to violate NRC requirements.- Enclosed-is our response to Appendix A, Notice

- of Violation. If you have any questions, please call Jim Domer at FTS 858-2725.

To the best of my knowledge, I declare the statements contained herein are complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY D1.)Vhd.

b.N. Mills, Manager Nuclear Regulation and Safety Enclosure 7FFICIAL COPk An Equal Opporturuty Ernployer

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