ML20054K254
| ML20054K254 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/16/1982 |
| From: | Kammer D TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20054K246 | List: |
| References | |
| NUDOCS 8207010338 | |
| Download: ML20054K254 (5) | |
Text
g.
TENNESSEE VALLEY AUTHORITY USNRCeWSyiMcic3,reuusssec3740, M T1., u t. a. v.+
"1 L,00 Chestnut Street Tower II h
82 JUN U
^3: 2June 16, 1982 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 in response to F. J. Long's May 17, 1982 letter to H. G. Parris, Report Nos. 50-259/82-13, -260/82-13, and -296/82-13, 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, pleaae 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 es M D. S. Kammer Nuclear Engineer Enclosure
~
8207010338 820624 gDRADOCK05000 An Equal Opportunity Employer 1
Y
ENCLOSURE RESPONSE - NRC INSPECTION REPORT NOS.
50-259/82-13, 50-260/82-13, 50-296/82-13 F. J. LONG'S LETTER TO H. G. PARRIS DATED MAY 17,1982 Appendix A Item A - 260/82-13-01 Technical Specification 3 5.F requires that the reactor core isolation cooling system (RCIC) shall be operable when irradiated fuel is in the reactor vessel and the reactor pressure is greater than 122 psig.
Contrary to the above, the requirement that the reactor core isolation cooling system be operable when irradiated fuel is in the reactor vessel and the reactor pressure is greater than 122 psig~ was not met in that on April 21, 1982, the reactor core isolation cooling system could not perform its intended safety function due to having its controller in the manual position.
The backup high pressure core spray system was inoperable for maintenance.
(The reactor operator was aware that the RCIC controller was in the manual-position and could be made fully operable by switching the controller to the auto position).
This is a Severity Level IV Violation (Supplement I.D.) and applies 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 As stated in the inspection report the RCIC controller was placed in manual position for the safety of personnel in the area during a steam leak inspection.
The procedure Surveillance Instruction (SI) 4,.5.F did not address these operations.
3 Corrective Steps Which Have Been Taken and Results Achieved The RCIC flow controller was placed in the automatic position immediately following leak inspection and notification of the inspector's finding.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations Surveillance instructions for high-pressure coolant injection (HPCI) and RCIC testing will be revised to include necessary operations to perform steam leak inspections following operation of the system.
These instructions will be in accordance with technical specification 4.2.B requirements for taking critical structures, systems, and components (CSSC) out of service for required tests and calibrations.
J
r-
. 5.
Date When Full Compliance Will Be Achieved Surveillance instructions will be changed by July 31, 1982.
Item B - (296/82-13-01)
Technical Specification 6.3.A requires that detailed written procedures be prepared, approved and adhered to for normal startup, surveillance and testing requirements.
1.
. Contrary to the above, the requirement that detailed written procedures be adhered to for surveillance and testing requirements was not met in the primary containment integrity was not established prior to exceeding 2100F primary system temperature on March 27, 1982 as required by Surveillance Instruction 3.3.1.A, Unit 3 Hydrostatic Test Procedure.
On March 27, 1982 at 10:00 p.m. and 11:00 p.m.,
primary coolant temperature was 211 F as measured by the strip chart' recorder on the discharge of recirculation pump A.
Various thermocouple readings of metal temperatures on the outside of the reactor vessel 0
also indicated 211 F temperature between 11:00 p.m. and 12:00 p.m.
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons For the Violation if Admitted Because of recent changes in temperature curves for hydrostatic testing, it has become necessary to maintain moderator temperatures as close to the upper limit as possible, in order to achieve the minimum vessel metal temperature.
In doing so, the 210 F limit was
- exceeded, s
3 Corrective Steps Which Have Been Taken and Results Achieved See response to Item 4.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations Future reac' tor pressure vessel hydrostatic tests (SI 3.3 1.A) and associated monitoring tests will be revised to clearly show temperature limits and provide procedural stops as necessary if limits are reached.
5.
Date When Full Compliance Will Be Achieved SI 3.3.1.A and associated procedures will be revised by August 15, 1982, which is before the next scheduled performance.
. Item B - (296/82-13-01) (Continued) 2.
Contrary to the above, the requirement that detailed written procedures be adhered to for normal startup was not met prior to the startup of Unit 3 on April 10, 1982, in that the correct position was not verified for three valves in the reactor core isolation cooling system and eight root valves for safety-related instrumentation as required on the valve lineup sheets.
(These valves had been improperly annotated as not requiring verification).
This is a Severity Level IV Violation (Supplement IV.E) and is applicable to Unit 3 1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons For the Violations if Admitted The three RCIC valves were not verified due to an oversight in the valve checklist by operators.
The eight instrument root valves were not verified because the operator misinterpreted the valve checklist to indicate that these valves were not applicable to unit 3 3
Corrective Steps Which Have Been Taken and Results Achieved The valves were immediately verified in the proper position.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations All system operating instructions are being revised to include an applicability statement which explains the system of unit prefix designation.
The event will be covered in operator supplemental training.
5.
Date When Full Compliance Will Be Achieved Operating instruction revisions will be completed by January 1, 1983 Supplemental training will be completed by September 30, 1982.
' Item C - (259/82-13-01)
Technical Specification 6 3.D.2 requires each High Radiation area in which the intensity of the radiation is greater than 1,000 mrem /hr. shall be provided with locked doors to prevent unauthorized entry.
.e
. Contrary to the above, the requirement that each High Radiation area be provided with locked doors was not met in that on April 21, 1982, the 1A Reactor Water Cleanup Pump Room was not locked and was not positively controlled to prevent unauthorized entry.
This room is posted as a High Radiation area.
A radiological survey was conducted on April 21, 1982 and the highest radiation reading was 1600 mrem /hr.
This is a Severity Level IV Violation (Supplement IV.D.) and is applicable to Unit 1.
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons For the Violations if Admitted The operations section instruction letter regarding control of access to high radiation areas once doors are unlocked is difficult to implement as written.
3 Corrective Steps Which Have Been Taken and Results Ac;.leved The requirements of technical specification 6.3.D.2 were discussed at a PORC meeting on June 4, 1982.
These supervisors are providing input into the plant procedure being developed.
(See item 4, below.)
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations A procedure will be developed to designate specific individual responsibility for door control whenever high radiation area doors are required to be maintained unlocked.
5.
Date When Full Compliance Will Be Achieved The procedure will be completed by August 1, 1982.
I 1
.