ML20053E063
| ML20053E063 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/17/1982 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20053E051 | List: |
| References | |
| NUDOCS 8206070571 | |
| Download: ML20053E063 (5) | |
Text
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TENNESSEE VALLEY AUJ;H,gTgggg,..
CH ATTANOOGA. TENNES5EC'd74MId, O f f G ' :
8 400 Chestnut Street Tower II 32 MAY 2*l A 8: 25 May 17, 1902 i
1 U.S. Nuclear Regulatory Commission Region II ATTN: James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
This is a supplemental response to R. C. Lewis' January 21 and March 15, 1982 letters to H. G. Parris, Report Nos. 50-259/81-37, -260/81-37, and I
-296/81-37, concerning activities at the Browns Ferry Nuclear Plant which appeared to violate NRC requirements. Our initial response was provided in my March 3, 1982 letter to you. 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
. M.
ills, Manager Nuclear Licensing Enclosure l
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50-259/31-27, 50-250/81-37, Al'D 50-296/9.1-37 R. C. LE'3I"' LETTER". 70 It. G. PADDIr DATED JA"UAPY 21, 1682 Af?D !'AP.Cli 15 and 18,1?"2 Ancandi:e A Technical 3nacification G.3.a recuires that detailed unitten crocedures shall be prepared, approved, and adbared to fcr radiation control and operaticn of svatern involving nucicar sarctv of the facilit'r.
Centrary to tha above, the renuirerent that detailad written procedures he prepared, approved and adhered to vas not met in that*
1.
Systen Operating Instruction (OI)-77, Operation of Padaste Disposal Systen, could not be used an written for reciret'latine the laundry drain tanks because of a nodification perfornad on the systen several years a,co and not incorporated into the procedure.
In addition, six valvan trere out of position as conpared to the cornal valve lineuo and one valve which was not on the normal valve lineup but was out of position as compared to the systen drawing.
2.
Containnent Atnos,bere Dilution Operating Instruction (DI-34) could not be used as waitten becaune the procedure referenced incorrect override locations and omitted required hand suitch naniculations thus nahing the nyster operation not possible if procedura) adherence was obeyed.
This is a Severity Level IV Violation (Sucplenent I.D.3.).
Resnonce 1.
Admission oe Denial of the Alleced Violation TVA admits the violation occurred as stated.
2.
Paanons for the Violation if Admitted 7::nnnie 1 The laundry drain tank recirculation piping uns nodified under a.
vorholan C270 and the nodification conoleted in Aurust 1979. The nodificaticn uas perforned to allou recirculation throur,h the laundry drain filter bercre cannlin.c. The nodification did not add or delete any valves or active components in the systen; hotrever, it did require a chanre to Operatinc Instruction (OI) 77 to open the filter inlet valve before recirculation. The chance uas not nade to OI-77 as required.
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5.
The six valves that uere found out of conition an coroared to the valve checklist were conoonents or the laundry drain avsten, radkaste evaporator systen, cle3n raduaste procencirc systen, nnd in the raduaste dischnrne to the cooline teuer blondoun. Three of the valves ucre out of positicn uith respect to thq valve checklint to perforn specific operations 1s described in 0I-77.
Tuo of the valves were out of the standby readiress positicn because the radusste evanorator systen uas not in service. The valve in the raduante discharge s"rten line to the coolinF tover 51oudenn cas out of the standby readiness position because the coolinn towers were not in servlee in the closed rode, and discherre fron radvaate to the cooling touer blowdoun line uns not desirable.
Movever, an abnornal status sheet uns not placed in the valve checklist file as renuired by Operations Section Instruction Letter (SIL) 21.
The valve checklist 9Ps intended to align the systen to the stand 57 readiness condition oer the desinn drawines and was not intended to provide aliennent for all nodes of systen operation. The valve aliennents for the codes are included in the ooeratine instruction.
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The valve that was not on the valve checklist was 77 P3h.
It is assened that this was a typonraphical crror. Pouever, OI-77 does address the use and position requirenents of this va]Ve on paFes 33 and 34 In cumnary, TVA's position regarding this exanole of the Violation is as follous:
1.
vhe valves uhich were "out of oositien" vere in reality in the proper position retarding operation of the particular subsysten, the oositions uere kncun to the operators, and the valves were in this position in accordance with the text of the operating instructions. Pacause of the nature of raduaste operations at Frowns Ferry (a continuous cycling betueen collection in a tank and discharge of the tank, with only a brier 30- to 60-minute recirculation-sanple cycle in betueen), it is not necessary or practical to restore the systen to standby readiness "on paper" af ter each subsysten operation.
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2.
TVA does concur that one valve was not on the valve checklist, one velve was out of position as reauired by the valve checklist, and the OI was out of date recarding tPO canipul3tien of recirculating the laundry drain tank.
3 There uere weaknesses in procedural discipline in our radwaste operations. This has been cited by MBC since this violation and additieral corrective measures have been taken as described under iten 4 below.
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The Containnent Atnesotere Dilutien / CAD) Evnten Oneratine Instruction (OI-04) k7d deficiencies uhich occurred nrir.aril" bonnuce of the nodification.mnde an n racult of n requirerent f"f!?EG-05?B) rocardinc recct of centninnent f rolatien cirnals.
The inftini TVA acpronch to this rodification "ns found not acceptable to 'TC durira a pontirolerentation reviau, and the synten uns required to be cdiflad a second tire.
At none stare of these rodifications, the reonired chances ware not rade to the operatirr,inntructicns.
I.
3 For ective " tens "hich Pave ? ann Tn'can and ?anulta Ackic"ad ixnrnia 1 DI-77 Mar been revi.,ed to correctiv include all nodificatien changes parrerned under uorkplen 3273.
A neu valve chac'Miirt har been run on radunsta svrters to encu-e crocer alinnr.ent of all valven lirtad in tre "al.vn chechlist. Ho"ever, as diccassed nbova, tha c"nten aliennent during enn given evolution uill be in acecrdance uith the procadure and ray deviate from tre valvo chec': list.
In addition, valve 77-314 vas added to the valve checklict.
Examnie P OI-C4 h?.c been revised to include correct suitch ranipulation and suitch locations for venting contairrant. OI Nh uns chanrad init ially after identification of the problan,by the inspector, but further drauinq revieu has conc]uded that the initial chance nas not su ffici ent,
h.
Corractiva Stenn Ubich "ill Pe Taken To Avoid Further "iolattenn Ernrrier 1 and 2 Perore the violaticn, Operatienn "IL 9h uns isnoed to inforn operators of the need to ider.tify orocedura eaaors and ensure they are corrected..
At that time, only licenced onerntorn vere on the readinc lint for crocedural changer (which included SIL 04).
Since that tine, the unlicensed anrintant shift encineer assicned to raduante operaticns hns bean added to this lint. Additionally, the requirenents of SIL Ch have been discussed with this individual.
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