ML20127K583
| ML20127K583 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/23/1985 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Parris H TENNESSEE VALLEY AUTHORITY |
| References | |
| EA-84-108, NUDOCS 8506270499 | |
| Download: ML20127K583 (4) | |
See also: IR 05000259/1984034
Text
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MAY 2 31985
Tennessee Valley Authority
ATTN: Mr. H. G. Parris
Manager of Power and Engineering
500A Chestnut Street Tower II
Chattanooga, TN 37401
Gentlemen:
SUBJECT:
REPORT NOS. 50-259/84-34, 50-260/84-34, AND 50-296/84-34
We have evaluated your response of February 27, 1985, to our Notice of Violation
and Proposed Imposition of Civil Penalties, EA 84-108, issued on January 28,
1985, concerning activities at Browns Ferry.
We find that your response to
Violation 6 meets the requirements of 10 CFR 2.201. We will examine the imple ~
mentation of your actions to correct Violation 6 during future inspections.
We have concluded that your response to the remaining violations does not meet
all the requirements of 10 CFR 2.201 for the reasons presented in the enclosure
to this letter. Please submit a written statement to this office within 30 days
of the date of this letter, which includes all information required by 10 CFR 2.201.
After careful consideration of the bases for your denial of Violation 7,
example B, we have concluded for the reasons presented in the enclosure to this
letter, that the violation occurred as stated in the Notice of Violation.
In addition, paragraph 5 of our January 28 letter asked you to address improve-
ments you have implemented or will implement in your Regulatory Performance
Improvement Program (RPIP) as a result of the identified violations.
The
attachment to your response only provided a discussion of the RPIP as it related
to corrective actions for the violations.
Please include in your supplemental
response those improvements you have made or will implement to the RPIP.
Under the authority of Section 182 of the Atomic Energy Act of 1954, 42 U.S.C.
2232, the response shall be submitted under oath or affirmation.
The responses directed by this letter are not subject to clearance procedures of
the Office of Management and Budget as required by the Paperwork Reduction Act of
1980, PL 96-511.
Sincerely,
ORIG!NAL SIGNED BY
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JOHN A. OLSHINSKl
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J. Nelson Grace
Regional Administrator
Enclosure:
Staff Assessment of Licensee Response
cc w/ enc 1:
(See page 2)
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Tennessee Valley Authority
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Enclosure:
Staff Assessment of Licensee Response
cc w/ enc 1:
J. A. Coffey, Browns Ferry
Nuclear Plant Site Director
G. T. Jones, Plant Manager
J. W. Anderson, Manager
Office of Quality Assurance
K. W. Whitt, Chief, Nuclear
Safety Staff
D. L. Williams, Jr. , Supervisor
Licensing Section
R. E. Rogers, Project Engineer
bec w/ enc 1:
NRC Resident Inspector
Document Control Desk
R. J. Clark, Licensing
Project Manager, NRR
State of Alabama
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ENCLOSURE
STAFF ASSESSMENT OF LICENSEE RESPONSE
Violation 1
a.
Under " Reasons for the Violation," Tennessee Valley Authority (TVA) states
" Maintenance Instructions were inadequate in that lack of comprehensive post
maintenance test requirements allowed the situation described by this
violation to occur undetected."
The reason the check valve FCV-75-26 was incorrectly assembled and what
corrective actions have been or will be implemented to prevent recurrence
were not provided.
b.
10 CFR 2.201(a)(3) requires the licensee's reply to a Notice of Violation
to include a date when full compliance is achieved.
No date was provided
in your response.
Violation 2
a.
Corrective steps you are taking to avoid further violations and the date
when full compliance will be or has been achieved were not provided,
b.
TVA should evaluate whether this surveillance should be performed during
power operation and initiate action as appropriate to have the Technical
Specifications modified.
Pending any change in requirements, this surveil-
lance procedure and any other procedures that challenge the interface
between the reactor coolant system and other low pressure systems outside
containment should be specifically reviewed to determine whether independ-
ent verification and sign off of key steps in the procedure should be
included.
Violation 3
As part of your corrective steps taken to avoid further violations, describe any
training TVA has performed to ensure that second party verification is
" independent" of the prescribed action and describe the date this training was or
will be completed.
Violation 4
a.
TVA states that a general policy of utilizing whole solenoids as replace-
ments has been instituted rather than the use of kits.
However, TVA also
states that prior to resumption of solenoid rebuilding operations, detailed
procedures will be required for assembly and verification of operability.
Please make clear in your supplemental response whether the solenoids will
be replaced whole or through the use of kits.
b.
As part of your corrective steps taken to avoid further violations, describe
what action TVA has taken to ensure that other spare parts for safety-
,
related equipment meet currently required quality levels.
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Enclosure
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Violation 5
a.
Please give dates when full compliance will be or has been achieved.
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b.
Describe any training that has or will be conducted to ensure that appro-
priate maintenance, engineering, and operating personnel understand the need
for good procedures and strict adherence to those procedures.
c.
Example C - TVA admits the violation, i.e., that the noted valves are not
equivalent in design characteristics and that no safety evaluation was
performed after the substitution.
However, TVA also states that the new
valve was an acceptable substitute and has requested further clarification
from the manufacturer.
In your supplemental response, please describe the results of any safety
evaluation you have performed subsequent to substituting valves.
Also,
describe what corrective measures have been or will be taken to ensure that
safety evaluations will be performed when required.
Violation 7
a.
Example A - Please describe any training conducted or planned to ensure that
appropriate personnel are aware of the need for post maintenance testing and
give a date when full compliance will or has been achieved.
b.
Example B - TVA denies the violation because the item was open at the time
of the inspection report.
They support this contention by referencing a
letter from D. Vassallo of the Nuclear Regulatory Commission to H. G. Parris
of Tennessee Valley Authority dated February 10, 1984.
After consideration of your reply, we reaffirm the violation as written.
You have presented no information that shews that the relief valves are not
required to be tested per ASME Section XI. The February 10, 1984 letter
referenced in your response specifically stated that valves 75-543A and B
should be included in the inservice testing program. While that letter may
have indicated that justification for omission of the valves could be
submitted, it in no way gave permission for TVA to continue to operate
outside the requirements of its license while it was determined whether such
justification existed.
The NRC espects, absent a specific finding to the
contrary, that licensees will take a cocservative approach in assuring
compliance with NRC regulations.
That is, when there is some question
whether an action is necessary to maintain compliance with the regulations,
that action should be taken until a determination is made that it, in fact,
is not required.
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