ML20040E586
| ML20040E586 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/23/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20040E585 | List: |
| References | |
| NUDOCS 8202050145 | |
| Download: ML20040E586 (6) | |
Text
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TENNESSEE VALLEY AUTMCFt(Tg,y,.
- O TO /j {,[A 400 Chestnut Street Tower II' 82 Ja q n8: 05 December 23, 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' November 24, 1981 letter to H. G. Parris, Report Nos. 50-259/81-232 -260/81-32, and -296/81-32, 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 J DO.)
, M.. Mills, Manager Nuclear Regulation and Safety Enclosure
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.. s ENCLOSURE RESPONSE - NRC INSPECTION REPORT NOS.
50-259/81-32, 50-260/81-32, 50-296/81-32 R. C. LEWIS' LETTER TO H. G. PARRIS DATED NOVEMBER 24, 1981 Item A 10 CFR 50, Appendix B, Criterion V as implemented by TVA Topical Report 75-1, Table 17.2-5 requires that activities affecting quality shall be prescribed by documented instructions and procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions or procedures.
Contrary to the above, the requirement that activities affecting quality shall be prescribed by documented instructions or proceddees and shall be accomplished in accordance with these instructions or procedures was not met in that 1.
The Nuclear-Quality Assurance Manual (N-0QAM) allows the shift engineer (SE)/ shift technical advisor (STA) to perform a review of emergency Trouble Reports (TRs) if the Quality Assurance (QA) staff is unavailable; however, no documented instructions, procedures or formal training was provided to the SE/STA in how to perform a QA staff review of TRs.
2.
TVA Topical Report 17.2.1 and N-0QAM 1.3.13 requires that the plant QA staff develop and implement a QC inspection or survei. lance program.
This instruction was not adequately implemented in that from June 1981 to September 1981 approximately 50% of all surveys scheduled to be performed by Quality Control (QC) personnel were not performed.
This is a Severity Level IV Violation (Supplement I.D.I.).
A-1 (259/81-32-02, 260/81-32-03, and 296/81-32-01) 1.
Admission or Denial of the Alleged Violation TVA admits a violation occurred.
We request that this violation be reclassified as severity level V.
The basis for this request is that the violation was a failure to implement a new N-0QAM requirement in a timely manner and was not a breakdown in the existing QA program.
At the time of the violation, the shift engineers (SEs) and shift technical advisors (STAS) were following issued plant instructions as prescribed by a memorandum from the assistant power plant superintendent (maintenance) that permitted work authorization reviews of emergency TRs, with a QA review required following the work to ensure acceptable procedures were specified and QA requirements were met. This memorandum did not reflect the August 1981 revision to the N-0QAM that requires prework QA review of all TRs and allows the SE/STA
in the absence of QA personnel to perform this QA review with an after-the-fact review by qualified QA personnel. The revised OQAM had not been fully implemented in that SEs/ STAS had not been trained in the QA review of TRs and the plant standard practice (SP) BF7.6 had not been revised to promulgate the 0QAM revisions. It has been TVA's experience that violations of this nature have been given a severity level of V.
2.
Reasons for the Violation if Admitted The reascns for the violation are stated above.
3 Corrective Steps Which Have Been Taken and Results Achieved All TRs are now receiving a prework QA review by a person designated by the OQAM qualified in the QA review of TRs. Until such time that other personnel receive required TR QA review training, qualified OA personnel are performing this review. Standard Practice BF7.6 has been written and approved to implement the August 1981 N-00AM TR review program.
4.
Corrective Steps Which Will se Taken To Avoid Further Violations All necessary corrective actions to avoid further violations have been implemented (as stated above).
5.
Date When Full Compliance Will Be Achieved TVA was in full compliance on December ':1, 1981, with the issuance of BF7.6.
A-2 (259/81-32-04, 260/81-32-04, and 296/81-32-02) 1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted Adequate attention by management was not given to the survey program and the performance of those personnel directly responsible for the program. Heavy inspection workload during the unit 1 refueling outage diverting manpower, failure of the individual charged with the inspection responsibility to inform his supervisor of the inability to fully comply with program requirements, and reorganization of the QA section during which there was only one management individual and no lead coordinator contributed to establishing conditions for the violation to occur.
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3 Corrective Steps Which Have Been Taken and the Results Achieved Since September 1, 1981, the entire survey program has been evaluated and modified. This evaluation included rewriting many surveys to make them more concise, reviewing standard practices to make sure the program was comprehensive, and modifying the survey schedule to reflect results found in previous surveys.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations An additional management employee has been assigned responsibility for the inspection and survey program.
As discussed in a letter from L. M. Mills to J. P. O'Reilly dated July 6,1981, regarding NRC Inspection Report 81-02, we have incorporated in our plant instructions provisions for consideration of personnel errors which lead to violations or deviations in preparation of employee service reviews. This event will be taken into consideration in preparation of the service reviews of employees.
In addition, a review of the survey program is scheduled every year.
5.
Date When Full Compliance Will Be Achieved All of the aforementioned actions were completed December 15, 1981.
Item B (260/81-32-01)
Technical Specification 3.5.F.2 requires that if the Reactor Core Isolation Cooling System (RCICS) is inoperable the High Pressure Coolant Injection System (HPCIS) shall be demonstrated operable immediately.
Contrary to the above, the requirement that HPCIS be demonstrated operable if RCICS is inoperable was not met, in that on September 1, 1981, flow indicator controller (FIC-71-36A) for RCICS was removed for calibration without demonstrating HPCIS operable. The controller was removed for approximately 10 minutes; however, operations personnel did not recognize that the RC7C system was inoperable.
This is a Severity Level IV Violation (Supplement I.D.2).
This is applicable to Unit 2.
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted Operations personnel were unaware that removal of FIC-71-36A made the RCIC system inoperable. Research was required by NRC and mechanical and instrument maintenance personnel to determine the system was inoperable.
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3 Corrective Steps Which Have Been Taken and the Results Achieved As noted in the violation, the flow indicating controller was returned to service within 10 minutes. Because the inoperability of RCIC was not determined for some time after the event, no other corrective action is applicable insofar as this particular event is concerned.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations Operations personnel will be instructed in supplemental training to take the conservative approach when doubt exists. The equipment being worked on will be considered inoperable when no definite determination can be made on operability related to instrumentation. Surveillance instructions (sis) will be performed as required if equipment is considered inoperable.
5.
Date When Full Compliance Will Be Achieved All groups will have reviewed the required information by February 1, 1982.
Item C (259/81-32-01) 10 CFR 50.72 requires that the licensee notify the NRC Operations Center within one hour by telephone of significant events including any event resulting in manual or automatic actuation of Engineered Safety Features, including the Reactor Protection System.
Contrary to the above, notification to NRC by telephone within one hour was not made on October 1, 1981 when Unit 1 reactor was tripped by the Reactor Protection System during preparation for a main turbine overspeed trip test.
This is a Severity Level VI Violation (Supplement I.F.).
This is applicable to unit 1.
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted The violation occurred because the SE was distracted and neglected to notify the NRC within the time prescribed. Major attention was directed to the determination of the cause for reactor low pressure which resulted in the reactor trip. Failure of the permanent magnet generator in the electric hydraulic controls (EHC) system caused alarms on the EHC system indicating EHC component failure. The cause determination was lengthy and took more than the one hour allotted to report. The cause of the trip was required on the report and was not determined in less than one hcur.
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_5-3 Corrective Steps Which Have Been Taken and the Results Achieved The operations supervisor talked to the SEs responsible for reporting.
They were instructed to report within one hour as required.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations In the future, SEs responsible for reporting will notify NRC within one hour even if the information normally reported is not available at the time.
5.
Date When Full Compliance Will Be Achieved Full compliance was achieved on October 2, 1981.
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