ML20127K583

Forwards Assessment of Licensee 850227 Response to Notice of Violation & Proposed Imposition of Civil Penalties,Per Insp Repts 50-259/84-34,50-260/84-34 & 50-296/84-34.Addl Info Requested within 30 Days to Meet 10CFR2.201 Requirements

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

,

I- bh cdo\

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

kDR $5 259 JOHN A. OLSHINSKl

G PDR

J. Nelson Grace

Regional Administrator

Enclosure:

Staff Assessment of Licensee Response

cc w/ enc 1: (See page 2)

d

IE

_ .. .

'

'

.

Tennessee Valley Authority 3

% 23 E

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

i

.

~~ _.

- .

• ~

>

_

, . = . . _ _ _

RII RII RII RII RII ^ '

ww w w RIIJ

WRuland:km FCantrell

9

DP4rre111 F.,j

0

rwa ker PB is3 GR en 'n s

.D4/J'//85A 04 ' w'07 O!/gh/ 85 e#df0,4/9 /85 4/85 O gg l/85

r k/tc spyr5 o

$

1

)h-

J01 qinski

85

.

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.

.. . .. - .. . - . . - - _ _ -

. _ _

O

Enclosure 2

Violation 5

a. Please give dates when full compliance will be or has been achieved.

'

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.

-_ --.. . . - . . _ _ , - - - - . . _