ML20076L680
| ML20076L680 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/30/1983 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20076L679 | List: |
| References | |
| NUDOCS 8309190034 | |
| Download: ML20076L680 (5) | |
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DQ, TENNESSEE VALLEY AUTHORITY ja
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CHATTANOOGA. TENNESSEE 374of g-400 Chestnut Street Tower II e
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g August 30,.1983 N~
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h U.S.-Nuclear Regulatory Commission Region II ATTN: James P.-O'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900-Atlanta, Georgia-30303
Dear Mr. O'Reilly:
Enclosed is our response to R. C. Lewis' July 29, 1983 letter to H. G. Parris transmitting Inspection Report Nos. 50-259/83-23, H
-260/83-23, -296/83-23 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 and Appendix B, Notice of Deviation. In a discussion
' between Jim Domer of my staff and Floyd Cantrell of your staff on August 29, 1983, a one-day extension to August 30 for submitting the response was discussed. 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 L. M. Mills,iManager Nuclear Licensing Enclosure
'9309190034 830908
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1983-TVA SOTH ANNIVERSARY An Equal Opportunity Employer
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RESPONSE - NRC INSPECTION REPORT'NOS.
50-259/83-23, 50-260/83-23, AND 50-296/83-23 R. C. LEWIS' LETTER TO H. G. PARRIS
' DATED JULY 29, 1983 Appendix A Item-A
-(260/83-23-04) 15 CFR'50, ' Appendix B, Criterion V requires activities affecting quality be prescribed:by documented instructions, procedures, or drawings of a type appropriate' to the circumstancss and shall be accomplished in accordance with these instructions, procedures, or drawings.
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Contrary to the above, the requirement was not met in that the Unit'2
, main steam relief valve tailpipe-10" redesigned vacuum breakers have not been installed in accordance with TVA drawing 47W401-10, workplan 10298, or the current revision 2 to the Unreviewed Safety Question
-Determination (USQD), sheet 7 to ECN P-0653 The pallet o-ring
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required by drawing 47W401-10 is not installed on any of the Unit 2 10" vacuum breakers.
This is a Severity Level IV Violation (Supplement I), 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 violation occurred as a result of late communications of.
installation details. Installation details were included in USQD information but not on the drawings. The lack of detail on the drawings-did not support the installation.or removal of the pallet o-rings during reassembly of the vacuum breakers. Drawing 47W401-F 10 was issued after'initialimodification work had been completed.
3 Corrective Steps Which Have Been Taken and the Results Achieved A revision to the.USQD has been issued. The revision does not require pallet o-rings to be installed. Additionally, a modified vacuum breaker is scheduled to be tested for life-of-plant operation on August 30 and 31, 1983 4.
Corrective Steps Which Will Be Taken To Avoid Further Violations Appropriate workplans will be revised to include the latest ~USQD information and drawing 47W401-10. Installation information will 4'
-be required to on the drawings as well as-within USQD information.
Additionally, design,information.which will effect startup of a j
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. unit will be transmitted immediately to Browns Ferry, especially if it concerns emergency modifications that are initiated during an outage.
5.
Date When Full Compliance Will Be Achieved Full compliance will be achieved by November 1, 1983, when revisions to the workplans have been approved.
Item B - (259, 260, 296/83-23-02) 0 Technical Specification 6.3.A.5 requires that detailed written procedures be adhered to as related to preventive maintenance procedures.
I Contrary to the above, the requirement was not met in that Mechanical Maintenance Instruction 116, Inspection and Maintenance of CSSC, Radiological, and Vital Area Doors, conducted on March 3, 1983, was not conducted in accordance with procedural requirements. Numerous doors were not inspected although required by procedure.
This is a Severity Level V Violation (Supplement I), and applicable to all Units.
1.
Admission or Denial of the _ Alleged _ Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted The general foreman erroneously omitted the inspection of all doors because some doors were inspected on scheduled maintenance and MMI-19 Other doors were omitted by oversight and were not identified during the review cycle by the cognizant engineer.
3 Corrective Steps Which Have Been Taken and the Results Achieved Foremen and review personnel have been instructed to complete all parts of plant procedures as instructed.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations MMI-116 will be revised to include all necessary doors. The data sheets will also be revised to list each door number that requires the semi-annual inspection so that it will be obvious to the foreman and the reviewer that a door has not been inspected.
5 Date When Full Compliance Will Be Achieved Full compliance will be achieved by September 15,1983, when
- MMI-116 will have been revised and performed.
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APPENDIX B NOTICE OF DEVIATION (259, 260, 296/83-23 P>3)
In Tennessee Valley Authority's latters dated December 2, 1977, September 1,1978, and a TVA/NRC Meeting of August 24, 1978, TVA committed to conduct an inservice test program to test for boral corrosion behavior. Boral _ test specimens were to be installed in the Unit 3 spent. fuel pool and periodically removed and examined to check long-term corrosion characteristics of boral sandwiched between type 304 stainless steel. The commitment was summarized in the Safety Evaluation to Amendment 42 of the. Unit 1 license,-Amendment 39 of the Unit 2 license, and Amendment 16 of the Unit 3 license. High density fuel storage racks containing boral were initially installed in September, 1978, with ongoing installations in all three units' spent fuel pools continuing in phases to the present time.
Contrary to the above, no spent fuel pool boral corrosion test program has been commenced as of the date of this report.
1.
Corrective Actions That Have Been or Will Be Taken Boral test specimens were received at Browns Ferry Nuclear Plant on December 21, 1978. Draft procedures for conducting the in-service test program were completed on June 17, 1980. Sample corrosion tests were conducted by TVA laboratories to determine guidelines for future inspection of actual boral test specimens used in the program. Precharacterization tests were performed on the specimens to be used in the program. These tests, completed by March 2, 1982, provided needed dimensional measurements. Discussions as to the method of-installation for the specimens were held. Safety requirements were determined and plans for installation completed.
These precharacterized boral test specimens were delivered to Browns Ferry.on June 14, 1983. The procedure for conducting the in-service test program has been completed and is awaiting approval.
Materials needed to install the specimens that are not now available are on order and are expected to arrive at Browns Ferry by September 26, 1983 The procedure for conducting the in-service test program will be approved and in effect by October 14, 1983 Boral test specimens will be installed in the unit 3 spent fuel pool by October 14, 1983, barring any delivery problems with the materials for installing the test specimens.
2.
Corrective Action Which Will Be Taken To Avoid Further Deviations Once the procedure for conducting the in-service test program goes into effect, specific time limits are set which mandate the removal and inspection of the boral test specimens.
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Date When Corrective Actions Were or Will~Be Completed Corrective actions will'be completed on October 14, 1983, with the installation of the boral test specimens $n the Browns Ferry unit 3 spent fuel pool.
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