ML20079J518

Responds to NRC Re Violations Noted in IE Insp Repts 50-438/83-28 & 50-439/83-28.Corrective Actions:Memo Emphasizing Awareness of Requirement That Heaters Remain Energized Issued & FSAR Revised to Reflect Exception

ML20079J518
Person / Time
Site:	Bellefonte
Issue date:	12/28/1983
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20079J500	List: ML20079J518
References
NUDOCS 8401240339
Download: ML20079J518 (3)

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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374ol 400 Chestnut Street Tower II December 28, 1983 U.S.' Nuclear Regulatory Commission Region II

. Attn: Mr. James P. O'Reilly, Regional Administrator t- 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

r BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 - RESPONSE TO VIOLATION r* 50-438/83-28 FAILURE TO MAINTAIN HEAT ON ERCW PUMP MOTORS AND RESPONSE j TO DEVIATION 50-438/83-28-01, 50-439/83-28 FAILURE TO SUBMIT AN FSAR REVISION IN A TIMELY MANNER PER CDR FINAL REPORT This is in response to R. C. Lewis' letter dated November 29, 1983, report ,

, -numbers 50-438/83-28, 50-439/83-28 concerning activities at the Bellefonte g Nuclear Plant which app 6ared to have been in violation of NRC regulations. ,

Enclosed is our response to the citations.  !

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If you have any questions concerning this matter, please get in touch with i R. H. Shell at FTS 858-2688.

f. To the best of my knowledge, I declare the statements contained herein are complete and true.

Very truly yours,

< TENNESSEE VALLEY AUTHORITY f .

. L. M. Mills,) Manager y Nuclear Licensing Enclosure "

cc: Mr. Richard C. DeYoung, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear; Regulatory Commission Washington,,9.C. 20555 s

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8401240339 840113 PDR ADOCK 05000438 0 PM 1983-TVA SOTH ANNIVERSARY An Equal Opportunity En.ployer

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, ENCLOSURE BELLEFONTE NUCLEAR PLANT UNIT 1 RESPONSE TO SEVERITY LEVEL IV VIOLATION 50-438/83-28-02 FAILURE TO MAINTAIN HEAT ON ERCW PUMP MOTORS Description of Deficiency 10 CFR 50, Appendix B, Criterion V, as implemented by TVA Topical Report No. TVA-TR75-1, Revision 5, Section 17.1A.5, requires that activities affecting quality be accomplished in accordance with prescribed instructions, procedures or drawings of a type appropriate to the circumstances. Procedures BNP QCP-1.2, Storage and BNP QCP-1.3, Maintenance require that motor heaters be energized while the motors are in storage.

Contrary to the above, on October 27, 1983, the four (4) ERCW Pump Motor Heaters were found deenergized by each feeder breaker being in the open position.

TVA Response

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

2. Reason for the Violation The equipment involved in this violation received an operation release on September 24, 1979 An operation release means that operation of this equipment is performed by TVA's Division of Nuclear Power (NUC PR) at the request of TVA's Division of Construction (CONST) in support of construction test activities.

Maintenance of this equipment, however, continues to be performed /

by CONST until system transfer to NUC PR.

Maintenance inspections are performed by CONST on a monthly basis, +

and the last inspection of this equipment on October 17, 1983, indicated that the heater breakers were energized and operating '

normally. Investigations by both NUC PR and CONST have failed to identify the reason the heater breakers were deenergized.

3 Corrective Steps Taken and Results Achieved At the time the violation was noted, the circuit breakers were closed and heat was returned to the ERCW pump motors.

4. Corrective Steps Taken to Avoid Further Violations A memorandum from CONST to NUC PR has been generated to place additional emphasis on this concern. The letter requested that i personnel responsible for operating this equipment be aware of the l requirement for the heaters to remain energized. By copy of this -

l memorandum, the appropriate CONST personnel were also notified of this_ concern.

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5. Date When Full Compliance Was Achieved .

,- TVA is now in full compliance.

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BELLEFONTE NUCLEAR PLANT UNZTS 1 AND 2 RESPONSE TO DEVIATION 50-438/83-28-01, 50-439/83-28-01 FAILURE TO SUBMIT A FSAR REVISION IN A TIMELY MANNER PER CDR FINAL REPORT Description of Deficiency In a final report for a CDR (BLRD 50-438/82-17 and SLRD 50-439/82-16) dated August 9,1982, the licensee stated that by Dacember 1, 1982 they would revise the FSAR to reflect an exception to Regulatory Guide 1.75.

Contrary to the above, to date the licensee has not submitted the FSAR revision. l TVA Response Admission or Denial of the Alleged Deviation TVA admits the deviation occurred as stated.

Corrective Action That Have Been or Will Be Taken TVA's Nuclear Licensing Staff (NLS) has maintained a system for tracking all commitments made to the NRC since November 1981.

Unfortunately, the FSAR revision commitment described above failed to be entered into the system. Due to the hundreds of items that have been stored and maintained in the tracking system without an occurrence, TVA believes this to be an isolated incident. This item has now been incorporated into the system and will be tracked and its status checked periodically. The FSAR will be revised to reflect the exception to Regulatory Guide 1.75.

Corrective Actions Taken to Avoid Further Deviations In order to avoid futher deviations, staff engineers will be periodically briefed by management on the importance of making certain that all recognized commitments made by TVA to the NRC are entered into the NLS commitment tracking system and are updated as necessary ,

and in a timely fashion.

Date Corrective Actions Will Be Completed The FSAR will be revised to reflect the subject exception by June 1, 1984. The commitment list was updated to include the missing material on December 22, 1983 Staff briefings concerning the importance of the completeness and timeliness necessary in maintaining a viable commitment tracking system have been held periodically over the past ,

several years and will continue to be held routinely.

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