ML20040G898
| ML20040G898 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/21/1982 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20040G891 | List: |
| References | |
| NUDOCS 8202160594 | |
| Download: ML20040G898 (5) | |
Text
v=
r
.. v.
TENNESSEE VALLEY AUTHORITY
' S t R C R E O D ri '*
h CH ATTANOOGA, TENNESSEE 3740
' 4T"*
"E W ".
1800 Chestnut Street Tower II January 21,1kk2 JM125 A10 : 54 Mr. James P. O'Reilly, Regional Administrator U.S. Nuclear Regulatory Commission Region II - Suite 3100 101 Marietta Street'?
Atlanta, Georgia 30303
Dear Mr. O'Reilly:
,4 c
This is in response to R. C. Lewis' December 22, 1981 letter to H. G. Parris, Report Nos. 50-259/81-35, -260/81-35, and -296/81-35, 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 i
858-2725.
.)
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY 0
k l
L. M.
ill. Manager Nuclear Regulation and Safety
/
Enclosure
, /'
c f
f l
l l
l l
l l
82'!2160594 820201
[
PDR ADOCK 05000259 l
O PDR An Equat Opportumty Emp; oyer
ENCLOSURE RESPONSE - NRC INSPECTION REPORT NOS..
50-259/81-35, 50-260/81-35, AND 50-296/81-35 R. C. LEWIS' LETTEL TO H. G. PARRIS DATED DECEMBER 22, 1981 Item A'(260/81-35-02)'
Technical Specification 3 7. A.6 requires that the differential pressure (DP) between the drywell and suppression chamber be maintained equal to or greater than 1.3. psid.
Contrary to the above, the requirements that the drywell and suppression chamber DP be maintained equal to or greater than 1 3 paid was not met in that on October 29,,1981, the DP between the drywell and suppression chamber on Unit 2 was at 1.25 psid.
This is'a-Severity Level IV Violation (Supplement I.D.). and. 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 The primary cause of this incident was a setpoint error on the drywell-to-torus differential pressure alarm system. The drywell-to-torus differential pressure air compressor was running in the manual mode per operating instructions, The alarm which would have alerted the operator to start the compressor had its setpoint below the technical d
specification limit of 1.3 psid.- This setpoint was based upon the original design data and had never been revised.
3 Corrective Steps Which_Have Been Taken and the Results Achieved Upon discovery of the incident, the operator immediately pumped the delta pressure up to greater than technical specification limit ot' 13 psid. Subsequently, on October 29, 1981, the alarm setpoint was changed to 1.32 paid to prevent recurrence.
- 4.. Corrective Steps Which Will Be Taken To Avoid Further Violations The alarm setpoints in Surveillance Instruction (SI) 4.2 F-17 were changed to greater than or ' equal to 1 3-psid. Unit 1 has a different setpoint because of torus modificationn and, therefore, is not affected. Unit 3 is in a refuel-outage and will have its setpoint verified correct with. respect to technical specifications before startup.
5.
Date When' Fell Compliance Will Be Achieved Full compliance on unit 2 was achieved on October 29, ~1981.
Full compliance.on unit 3 will be before the startup from the present refuel outage.. No recurrence control is necessary on unit 1 as explained above.
Y a
a
.- Item B - (259/81-35-01, 260/81-35-01)
Technical Specification 3 2.E requires that instramentation that monitors drywell leaks meet the limiting conditions of operation as given in Table 3.2.E.
Table 3 2.E requires that the drywell air sampling system setpoint for alarm be set at 3X average background for gaseous and particulate activity.
Contrary to the above, the requirement that the drywell air sampling system setpoint be set at 3X average background for gaseous and particulate activity was not met in that on November 3, 1981, the drywell sampling continuous air monitor alarm set point was set at a value required by the surveillance instruction which was not directly related to average background. The setpoints were found to vary from two to 35 times the average background.
This is a Severity Level V Violation (Supplement I.E.)
and applicable to Unita 1 and 2.
1.
Admission or Danial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted Surveillance Instruction (SI) 4.2.E-2 was deficient in that it did not revise setpoints according to a fluctuating background. This was an oversight in the instruction.
3 Corrective Steps Which Have Been Taken and the Results Achieved The setpoints were revised to agree with the 3X background requirement within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations SI 4.2.E-2 was revised to incorporate the 3X background requirement in full compliance with technical specifications.
5.
Date When Full Compliance Will Be Achieved SI 4.2.E-2 was revised on December 1, 1981.
Item C (259/81-35-02)
Technical Specification 4.8.B.1.a requires that for effluent streams having continuous monitoring capability, the activity and flow rate shall be monitored and recorded to enable release rates of gross radioactivity to be determined on an hourly banis.
f.
. Contrary to the above, the requirement that activity and flow rate be monitored and recorded on an hourly basis was not met in that on August 16, 1981, hourly samples were not obtained on the Unit 1 Reactor Building ventilation exhaust when the installed continuous air monitor was inoperable.
This is a Severity Level V Violation (Supp?.ement IV.F.). and is applicable to Unit 1.
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reascns for the Violation if Admitted The cat
- was declared inoperable by the shift engineer who notified the day shift radiochemical laboratory analyst (RLA) at 1410. The evening shift RLA who came on duty at 1430 failed to fully understand the status of the CAM. Following a personal observation of the CAM he incorrectly assumed it to be operable. He then exceeded his authority by relaxing the prescribed sampling frequency.
3 Corrective Steps Which Have Been Taken and the Results Achieved This incident has been discussed with the RLA who made the error.
SI 4.8.B.1.a.2 was revised on December 28, 1981, to aid transmittal of abnormal CAM status from shift to shift.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations The indiviudal committing the error will be disciplined in writing for the failure to follow laboratory procedures governing CAM inoperability requirements.
- i. Date Wnen Full Compliance Will Be Achieved Full compliance will be achieved by February 2, 1982, when disciplinary action will be completed.
Item D (259/81-95.03, 260/81-35-03, 296/81-35-01)
Technical Specification 6.3. A.7. requires that detailed written procedures shall be adhered to for radiation control procedures. Radiological Control Instruction 10 requires that prior to entry into a contaminated zone a special work permit shall be issued.
m a. w a. _
3
,a., b'
- Contrary to the above, the requirement that a special work permit is issued prior to entrance into a contaminated area was not mec in that on November 9, 1981, several workers entered a contaminated area on the refuel floor without the issuance of a special work permit.
This is a Severity Level V Violation (Supplement IV.E.). applicable to Units 1, 2, and 3 1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted The foreman involved was under the mistaken impression that the contaminated zone area which was established had not been used, was clean, and could therefore be removed. He failed to check with the health physics technicians at the control point nor did he use a special work permit to perform the cleanup and removal of the contaminated zone area.
3 Corrective Steps Which Have Been Taken and the Results Achieved Health physics issued a radiological incident ceport.
This matter was immediately discussed with the foreman responsible for this violation; and he was given a disciplinary action letter for violating health physics procedures. The foreman has been briefed on health physics requirements. The laborers and boilermakers assigned to the refuel floor were briefed on this incident.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations No further corrective actions are required. See item 3 above.
5.
Date When Full Compliance Will be Achieved Full compliance was achieved on January 2, 1982, when corrective actions were completed as stated above.
_ _ _ _ _ _