ML20205F218
| ML20205F218 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/21/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8810280013 | |
| Download: ML20205F218 (4) | |
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TENNECCEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401 5N 1578 Lookout Place OST 211988 U.S. Nuclear Regulatory Commission
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ATTN: Docu;nent Control Desk Washington 0.C.
20555 Gentlemen:
1 in the Matter of
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260 i
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50-296 l
1 BR0HNS /ERRY NUCLEAR PLANT (BFN) UNITS 1, 2, AND 3 - NRC INSPECTION REPORT NOS. 50-259/88-18, 50-260/88-18, AND 50-296/88-18. - RESPONSE TO NOTICE OF VIOLATION - 10 CFR 50, APPENDIX B, CRITERION V j
i This letter is to provide TVA's response to the notice of violation r
transmitted in the subject report.
This notice of violation was sent from i
F. R. McCoy to S. A. White dated September 22, 1988.
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The report cited TVA with one violation 'n the restart test area for not I
i processing a concitton adverse to quality (CAQ) report even though the noted i
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event was described as significant in revision 4 of the Nuclear Quality l
Assurance Manual.
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j Enclosure I provides background information and TVA's response to NRC concerns raised in the subject report and reflects that TVA's corrective action has been completod.
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t If you have any questions, please telephone B. S. Schofield at 205/729-2636.
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Very truly yours.
4 TEN ESSEE V LLEY AUTHORITY l
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R. Gridley,/ anager j
j Nuclear Lipensing and i
Regulatdry Affairs l
1 Enclosures cc:
See page 2 I
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8810280013 SS1021 i
PDR ADOCK 0500o259 l
An EquM Opportunity Employer
U.S. Nuclear Regulatory Comission OST 211988 cc (Enclosures):
Hs. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. F. R. McCoy, Acting Assist &nt Director for Inspoction Programs l
TVA Projects Division l
U.S. Nuclear Regulatory Commission Region !!
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101 Harletta Street, NW, Suite 2900 Atlanta, Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 12. Box 637 Athens, Alabama 35611 l
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ENCLOSURE 1
RESPONSE
NRC INSPECTION REPORT NOS. 50-259/88-18, 50-260/88-18, AND 50-296/88-18 LETTER FROM F. R. McC0Y TO S. A. HHITE DATED SEPTEMBER 12, 1988 Violation During the NRC inspection conducted on June 12-30, 1988, a violation of NRC requirements was identified.
The violation involved failure to initiate a Condition Adverse to Quality Report (CAQR) following an inadvertent overload of the 1/2 "0" diesel generator.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the violation is listed below:
10 CFR 50, Appendix B, Crite.*lon V requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
The Nuclear Quality Assurance Manual, Part I, Section 2.16, Step 2.1.1.F 1mplements this requirement by specifying that a condition adverse to quality (CAQ) shall be documented ca a CAQR for items which have been subjected to conditions for which they have not been designed such as overpiessure, overvoltage, overheating, overstressing, or excessive environmental conditions.
Further, Step 2.1.1. A requires a CAQR be initiated for items that have failed or malfunctioned.
Contrary to the above, a CAQR was not generated to document a condition adverse to quality that occurred during the conduct of Special Test 88-09, Diesel Generator Governor and Voltage Regulator Calibration, on June 21, 1988.
Diesel Generator "0" was inadvertently overloaded for a period of 30 seconds during w5tch time the control room indications of kilowatts (KW), kilovars (KVAR), and amperage (AMPS) were off$cale high.
The malfunction was, in part, a result of a failed GE SBN switch in the diesel generator breaker compartment.
This is a severity level IV violation and is applicable to all three units.
TVA Response 1.
Admission or Denial of the Alleged Violation TVA admits the violation.
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2 2.
Reasons for the Violation if Admitted At the time of the event, field personnel were using an approved site procedure Site Ofrector Standard Practice (50SP) 3.7, "Corrective Actions," for significant CAQ determination. Under the guidance provided in 50SP 3.7, which complied with Revision 3 of the Nuclear Quality Assurance Manual (NQAH), the overvoltage condition could be documented and investigated as a test discrepancy.
Revision 4 of the NQAM, which had been approved but not implemented at the time of the event, provides more detailed guidance to be followed during CAQ significance determination.
Revision 4 of the NQAM had undergone preliminary distribution to allow for training and for site procedure updating before actual implementation.
Had Revision 4 of the NQAM been implemented through plant procedures at the time of the event, a CAQR would have been required.
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Corrective Steps Which Have Been Taken and Results Achieved In a Site Director Staff meeting held on July 18, 1988, the Browns Ferry Nuclear Plant Site Olrector stated that a more aggressive attitude must be developed when evaluating CAQs.
He further stated that whenever personnel are "in doubt," a CAQR should be initiated and subsequent evaluation used to establish its validity.
This management position is documented in a memorandum from G. G. Turner to Those listed (Principal Managers) dated July 21, 1988.
In addition to the added management attention, SDSP 3.13. "Corrective Actions," has been written and implemented.
This procedure provides guidance for CAQ evaluation which is consistent with Revision 4 of the NQAM.
On July 7, 1988, a CAQR (BFP880475) was generated to insure the proper disposition of this incident.
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Corrective Stept Which Will Be Taken to Avoid Further Violations l
No further corrective actions are required.
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Date When Full Compliance Will Be Achieved l
Full compliance was achieved upon implementation of SDSP 3.13.
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