ML20203K399
Text
,
e 3
1 r
r TENNECOEE VALLEY AUTHORITY CH ATT/.NOOGA. TENNESSEE 374o1 April 27, 1973 Mr. llorman C. Moseley, Director Directorate of Regulatory Operations U.S. Atomic Energy Commission
/
Region II - Guite 618 230 Peachtree Street, W.
Atlanta, Georgia 30303
Dear Mr. Moseley:
T This is in response to your !! arch 29, 1973, letter RO:II:WSL 50-259/73-3 on the subject of an inspection
]
conducted by DRO Inspector W. S. Little on February 20-22, 1973, at our browns Ferry Nuclear Plant. The items, which Mr. Little stated appear to be in viclation of 10 CFR 50, Appendix B, have been investigated, and we are submitting; the enclosed response on each reported iten.
Very truly yours, oh J. E. Gilleland L
Assistant to the Manager of Power Enclosure i
7 Y
8604300302 860317 e
//
we
. Resnonse to RO: I:UCL S0-269/73-3 Enclosure I.A l.a.
This was answered satisfactorily during Mr. Little's inspection.
E I.A.l.b.
The cleanup of the wood debris in and around.the CRD guide tube and in the stean separator and dryer units was made in accordance with Construction Procedure No.
3F-42, Instructions for-Access and Cleanliness Control for Reactor Assembly. This proconure nas been in effect since Hay 8,1970, and was considered appropriate for this cleaning activity as the work nethods vere essentially the sano as employed to obtain original cleanliness. TVA does not consider this a violation of Appendix B, Criterion VI.
I.A.2.a.
The flushing procedure used for performances of the flushes to establish final cleanliness required recording the jet pump differential pressure reacings. The pur-pose of such readin.;c was to determine that none of the jot pumps were blocked.
No attempt was made to compare readings with that required by*the recirculation systen preoperational test as the only interest was in deternining that lines were clear. TVA does not foci that a violation of Appendix B, Criterien XI, occurred.
I.A.2.b.
The RPV flushing procedure used for the first flush did not contain requircaents for reporting results. The procedure for the second flush did contain acceptance criteria and requirements for reporting results achieved.
Evaluation of the results van discucced in a necting of all interested parties on January 7, 1973. At this necting the decision van nade,to accept the results and to prcceed uith vcasol araining. The documentation of this meeting was not available to the inspector during his visit, but is covered by tne summary report of this incident dated March 8, 1973. TVA nay have been at fault for not preparing documents as work progressed, but adequate notes were kept to prepare an accurate sunnary report of the event. Efforts to alert all personnel to the requirenents of 10 CFR 50, Appendix If," Criterion XI, uill continue.
I.A.3.
Any lack of documentat on' in regard to the cleanup of the wood debris in the HPV and n'ttached systens has been corrected by preparation of the summary reporf'of March 0, 1973, filine this with the reports of flushes and report of inspection after draining. These documents have'bcen pinced in the pernanent records of the plant, and a copy has been provided the inspector. TVA considers that they are now in full com-pliance with 10 CFH So, Appendix B, Criterion XVII.
o i
e t
D
i 7 dNNEDPEE VALLEY AU1.40AITY l
~
CHATTANOOGA, TENNESSEE37401 40
$NE$$"$E AAATNEASHip May 23, 1973 Mr. Norman C. Moseley, Director Directorate of Regulatory Operations U.S. Atetic Energy Coc=ission Region II - Suite 818 230 Peachtree Street, IN.
Atlanta, Georgia 30303
Dear Mr. Moseley:
This is in response to your March 29, 1973, letter RO:II:WSL 50-259/73-3 on the subject of an inspection conducted by DRO Inspector W. S. Little on February 20-22, 1973, at our Browns Ferry Nuclear Plant. The items, which Mr. Little stated appear to be in violation of 10 CFR 50, Appendix B, have been investigated, and we are submitting the enclosed response on each reported item. This letter and enclosure supersede y letter of April 27, 1973, and its enclosure.
Very truly yours,
\\.
L A
Q" J. E. Gilleland
/
Assistant to the Manager of Power Enclosure i
l
'/,
s e.
_ Response to RO:II:'g'SL 50-259/73-3 Enclosure I.A.l.a.
This was answered satisfactorily during Mr. Little's inspection.
I.A.l.b.
The cleanup of the wood debris in and around the CRD guide tube and in the steam separator and dryer units was made in accordance with field procedure entitled " Cleanup Procedure for Unit 1 Shroud Head and Separater and Steam Dryer," and in compliance to cleenliness criteria found in BF h2, Instructions for Access and Cleanliness Contrcl for Reacter Assenbly.
Although General Electric site engineers participated in
~
the preparation of the cleanup procedure and concurred in all respects, formal concurrence was not received until after cleanup work was co=plete. To prevent future violations of this nature, written instructions have been issued to retponsible project personnel to allow no work until formally approved procedures have been received.
I.A.P.a.
The flushing procedure used for performance of the flushes to establish final cleanliness required recording the jet pu=p differential pressure readings. The purpose of such readings was to determine that none of the jet pu=ps were blocked.
No attempt was made to compare readings with that required by the recirculation system preoperational test as the only interest was in deter =ining that lines were clear.
The procedure did not speciP/ the purpose or acceptance criteria; hcvever, those perfor=ing the test were cognicant of both purpose and acceptance criteria.
To prevent future violations of this type, written instrue-tions have been issued to persons responsible for procedure preparaticn sad implementation to ascertain that acceptance criteria are included in all procedures where appropriate.
I.A.2.b.
The RPV flushing procedure used for the first flush did not contain requirements for reporting results. The procedure for the second flush did contain acceptance criteria and requirements for reporting results achieved.
Evaluation of the results was discussed in a meeting of all interested parties on January T,1973. At this meeting the decision was made td accept the results and to proceed with vessel draining. The docu=entation of this meeting was not available to the inspector during his sisit, but is covered by the su= mary report of this f acident dated March 8,1973. ' TVA may have been at fault for not preparing doeurents as work progressed, but sdequate noces vr.re kept to prepare an accurate su=cary report of the event.
E.' forts to alert all personnel to the requirements of 10 CFR 50, Appendix B, Criterien XI, vill continue.
t
e;.
Any lack of documentation in regard to the cleanup of the I.A.3 wood debris in the RPV and attached systems has been corrected by preparation of the su= mary report of March 8, 1973, filing this with the reports of flushes and report of inspection after draining. These documents have been placed in the permanent records of the plant, and a copy has been provided the inspector. TVA considers that they are now in full compliance with 10 CFR 50, Appendix B, Criterion XVII.
9 e
4