ML20058B823
| ML20058B823 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/06/1982 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20058B817 | List: |
| References | |
| NUDOCS 8207260159 | |
| Download: ML20058B823 (4) | |
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TENNESSEE VALLEY AUTHORITY CH ATTANOOG A. TENNESSEE 374o1 yy 400 Chestnut Street Tower II
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July 6, 1982
- l0 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:
Enclosed is our response to R. C. Lewis' June 4, 1982 letter to H. G. Parris transmitting Inspection Report Nos. 50-259/82-16,
-260/82-16, -296/82-16 regarding activities at our Browns Ferry Nuclear Plant which appeared to have been in violation of NRC regulations. We have enclosed 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 knowle 'ae. I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY n.
f L. M. Mills, Manager l
Nuclear Licensing Enclosure 8207260159 020715 PDR ADOCK 05000259 G
ppg An Equal Opportunity Employer
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ENCLOSURE RESPONSE - NRC INSPECTION REPORT NOS.
1 50-259/82-16, 50-260/82-16, AND 50-296/82-16 j
R. C. LEWIS' LETTER TO H. G. PARRIS DATED JUNE 4,1982 1
Appendix A Item A - (259/82-16-01)
Technical Specification 3.5.E.2 requires that if the High Pressure Coolant Injection (HPCI) system is inoperable, the reactor may remain in operation for a period not to exceed seven days, provided the Automatic Depressuri-zation System (ADS), Core Spray System (CSS), Residual Heat Removal System (Low Pressure Coolant Injection (LPCI) mode) and Reactor Core Isolation Cooling (RCIC) are operable.
Contrary to the above, the requirements that the CSS and RHRS be operable if HPCI is inoperable was not met on May 12, 1982, in that the 1 A Core Spray (CS) pump and the 1 A Residual Heat Removal (RHR) pump had their respective breakers racked out, rendering the pumps inoperable, while the HPCI system was inoperable for surveillance testing of the HPCI r6om temperature indicators.
This is a Severity Level IV Violation (Supplement I.D.2) and applicable to Unit 1.
1.
Admission or Denial of the Alleged Violation i
TVA admits the violation occurred as stated.
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2.
Reasons for the Violation if Admitted i
The root cause was procedure deficiency combined with lack of communication.
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Corrective Steps Which Have Been Taken and the Results Achieved The testing on 4-kV shutdown board breakers has been deferred until required procedure changes have been made and approved.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations Specific Maintenance Instruction (SMI) 1 will be revised to include signoff steps for the shift engineer, assistant shift engineer, and unit operator for the. units affected, which will ensure they have been informed before the test performance of the equipment to be removed l
from service. In addition, the test engineer will communicate with the unit operator during the performance of the test and coordinate the removal of equipment from service. Signoff steps will be provided to ensure this test engineer / unit operator coordination is properly l
performed.
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Also the llPCI surveillance instruction (SI) which was being performed is being revised to ensure that other core standby cooling systems are operable, along with a similar RCIC SI change.
In addition, plant standard practices are being revised as described in our response ta item B.2 below to ensure the event does not recur.
5.
Date When Full Compliance Will Be Achieved i
Plant standard practice changes will be issued by July 16, 1982.
Changes to SMI-1 will be made by. December 31, 1982. SI changes.will be completed by July 31, 1982.
Item B - (259/82-16-02, 260/82-16-01)
Technical Specification 6.3.A requires that detailed written procedures shall be prepared, approved, and adhered to for normal operation of all systems and components involving nuclear safety of the facility.
Contrary to the above, the requirement that detailed procedures be prepared and adhered to for operation of components of systems involving nuclear safety was not met in that:
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The Shift Engineer was not informed as required by Standard Practice l
12-17, Administrative Controls for Plant Operations, that the test conducted on the "A" 4kV shutdown board, per Specific Maintenance
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Instruction-1, on May 12, 1982, involved racking out the breakers for the 1A and 2A RHR pumps and the 1A and 2A core spray pumps.
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A procedure had not been issued to implement TVA's December 23, 1980, response to TMI Action Item I.C.6, paragraph 4 which stated that equipment status would not be changed without approval of the reactor operator.
This is a Severity Level IV Violation (Supplement I.D.2.) and is applicable to Unit 1 and 2.
B.1 3
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Admission or Denial of the Alleged Violation i
TVA admits the violation occurred as stated.
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Reasons For The Violation if Admitted The shift engineer was 'not fully informed regarding the detailed steps of S:11-1 which removed equipment from service by racking out breakers.
Tne written instruction did not require notification of the shift engineer or ' unit operator before racking out a breaker.
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.= 3 Corrective Steps Which Have Been Taken and Results Achieved SMI-1 will not be performed until it has been revised to include steps which ensure that adequate communications between the test engineer and
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operating staff have been conducted.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations SMI-1 will be revised to include signoff steps for the shift engineer, assistant shift engineer, and unit operator for the units affected, which will ensure they have been informed before the test performance-of the equipment to be removed from service. In addition, the test engineer will communicate with the unit operator during the performance of the test and coordinate the removal of equipment from service.
t Signoff steps will be provided to ensure this test engineer / unit operator coordination is properly performed.
5.
Date When Full Compliance Will Be Achieved a
SMI-1 will be revised by December 31, 1982.
B-2 1.
Admission or Denial of the Alleged Violation 4
TVA admits the violation occurred as stated.
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Reasons for the Violation if Admitted
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l Our response to the TMI action item was intended to provide notification to the operator through the normal chain of command (shift engineer, assistant shift engineer, unit operator). Because of the increased responsibility and workload on the shift engineer, this has not proved to be completely adequate.
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3 Corrective Steps Which Have Been Taken and Results Achieved i
Changes to plant standard practices have been initiated to clarify this I
requirement.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations Standard practice changes which were initiated are in review.
Changes to BF 12.5 and 7.1 will be issued after completion of review.
5.
Date When Full Compliance Will Be Achieved BF 12.5 and 7.1 will be revised by July 16, 1982.
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