ML20127B426

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Responds to NRC Re Violations Noted in Insp Repts 50-259/85-09,50-260/85-09 & 50-296/85-09.Corrective Actions: Surveillance Instruction 4.2.F.18 Re Relief Valve Tailpipe & Operating Instruction 30 Re Damper Position Revised
ML20127B426
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 04/22/1985
From: Domer J
TENNESSEE VALLEY AUTHORITY
To: Grace J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8506210466
Download: ML20127B426 (3)


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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA, TENNESSEE 37401

. 400, Ches%qt*,S{r$et Tower II b,,3 h t n ' "

April 22, 1985 U.S. Nuclear Regulatory Commission Region II ATTN:

Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

Dear Dr. Grace:

BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 - NRC-0IE REGION II INSPECTION REPORT 50-259/85-09, -260/85-09, -296/85 RESPONSE TO VIOLATION Enclosed is our response to D. M. Verrelli's March 22, 1985 letter to H. G. Parris transmitting IE Inspection Report Nos. 50-259/85-09, 50-260/85-09, and 50-296/85-09 for our Browns Ferry Nucicar Plant which cited TVA with one Severity Level V Violation.

If you have any questions, please get in touch with R. E. Alsup 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 J. A. Domer Nuclear Engineer Enclosure oc (Enclosure):

Mr. James Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Records Center Institute of Nuclear Power Operations 1100 circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 0506210466 850422 PDR ADOCK 05000259 0

PDH

%g An Equal Opportumty Employer

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RESPONSE

NRC INSPECTION REPORT NOS.

50-259/85-03, 50-260/85-09, AND 50-296/85-09 D. M. VERRELLI'S LETTER TO H. G. PARRIS; DATED MARCH 22, 1985

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Item 1.A Technical Specification 6.3.A requires that detailed. written procedures, including applicable check-off lists, shall be prepared, approved and adhered to for operations and surveillance requirements.

Contrary to the above, this requirement was not met in that the Surveillance Instruction 4.2.F.18 (" Main Steam Relier Valve Thermocouple and Acoustic Flow Monitor") did not include appropriate acceptance criteria to ascertain whether the recorded values met the " consistency and nominally l

expected value" criteria.

1.

Admission or Denial of the Alleged Violation TVA admits the violation as stated.

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2.

Reasons For the Violation Surveillance Instruction (SI) 4.2.F.18 was deficient in that there were no nominally listed values for relier valve tailpipe temperature and output signals for the subject instruments.

3.

Corrective Steps Which Have Been Taken and Results Achieved

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A general revision to SI 4.2.F.18 was made on March 5, 1985. Included in this revision was a nominal range for relier valve tailpipe temperatures and for expected output from the acoustic monitor.

4.

Corrective Steps Which Will Be Taken to Avoid Further Violations No further action is required.

5.

Date When Full Compliance Will Be Achieved i

Full compliance has been achieved.

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Item 1.B l

Technical Specification 6.3. A requires that detailed written procedures,

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including applicable check-off lists, shall be prepared, approved and adhered to for operations and surveillance requirements.

Contrary to the above, the requirement was not met in that the required position of dampers 0-30-503, 504, 505 and 506 in the valve checklist contained in Operating Instruction 30 aVentilation System" was ambiguously stated ("0 PEN TO PRESET POSITION") such that operators were unable to determine the correct required position. This was a contributing cause to a damper misalignment event on January 14, 1985 which resulted in airborne radioactivity in the radwaste building in excess of 10 CFR 20 maximum permissible concentration. (Xe 135).

1.

Admission or Denial of the Alleged Violation TVA admits to the violation as stated.

2.

Reasons For the Violation Normal operation of the radwaste ventilation exhaust system requires that the dampers for the filter train in service be open and the dampers for the out-of-service train be closed. Thus, the dampers for each train could be open or closed depeadent on the filter train that is in service. Operations Instruction (OI) 30 was deficient in that it specified that all four dampers be open to preset position rather than requiring that dampers be open for the filter train that is in service and closed for the out-of-service filter train. We believe damper misalignment was caused by either vibration causing the damper to close or personnel error.

3 Corrective Steps Which Have Deen Taken and Results Achieved, OI 30 was revised on March 8, 1985, with a note specifying that one exhaust filter train be in service at a time, and the damper position required when each train is in service. The damper position checklist has been revised to require that the damper position be recorded. This revision to 0130 also requires second party verification for damper position. Besides these procedural changes, the dampers for the filter train in service have double nuts installed as a locking device, and the room where these dampers are located is locked.

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Corrective Steps Which Will Be Taken to Avoid Further Violations No further action is required.

5.

Date When Full Compliance Will Be Achieved Full compliance has been achieved.

The above two items constitute one Severity Level V violation applicable to all units.

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