ML18025B469

Responds to NRC 810310 Ltr Re Violations Noted in IE Insp Repts 50-259/80-47,50-260/80-37 & 50-296/80-41.Corrective Actions:Shield Plugs Installed & Marked to Indicate That Plugs Cannot Be Removed W/Plant at Power

ML18025B469
Person / Time
Site:	Browns Ferry
Issue date:	04/06/1981
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML18025B466	List: ML18025B469
References
NUDOCS 8105010123
Download: ML18025B469 (8)

Text

TENNESSEE VALLEY AUTHORITY'"'(", P; ";,'.i, p% ~

CHATTANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II < ~

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April 6,, 1981 Mr. James P. O'Reilly, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region II, Suite 3100 101 Marietta Street Atlanta, Georgia 30303'ear Mr. 0!Reilly:

This is in response to R. C. Lewis'arch 10, 1981, letter to H. G. Parris, Report Nos. 50-259/80-47,, -260/80-37, and -296/80-41, concerning activities at the Browns Ferry Nuclear Plant which .appeared to violate NRC requirements. Enclosed is our response to Appendix A Notice of Violation. If'you have any questions, please call Jim Domer at FTS 857-2014.

I declare 0 To the best of my knowledge, are complete and true.

Very the statements truly yours, contained herein TENNESSEE VALLEY AUTHORITY'

. M. Mills, nager Nuclear Regulation and Safety Enclosure 81OOOZO

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An i=noel Oonnrtnnitv Ernolover

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ENCLOSURE RESPONSE TO R. C. LEWIS'~CH 10, 1981, LETTER TO H. G PARRIS (50-259/80-47, -260I80-37, -296/80,",41)

Violation A*

10 CFR 50.59(a) (1) permits a licensee to make changes in, the facility as described in the safety analysis report without prior .Commission approval, unless the proposed change involves a change in the technical specification or an unreviewed safety question. Changes to the Hydrogen-Oxygen (H -0 )

monitoring system as described in the safety analysis report,.section2 5.2 2 were made and included a written safety evaluation. The safety evaluation required that during plant operation, the torus access shield plugs must remain installed u'nless- another safety evaluation is made go determine if the cooling water s'upply to the H -0 monitor was adequate for a post loss of coolant environment.

Contrary to the above,.: on December 2, 1980, the inspector observed that the torus access shield plugs were not insta1led while unit 2 was operating at power with no safety evaluati'on having been performed to determine the cooling water supply to the Hayes-Republic H -0 monitor was adequate if if a loss of coolant accident. occurred.

eI e 2 2 e

This is a Severity Level IV Violation (Supplement I.D.1) applicable to unit 2.

I Admission or Denial of the Alle ed Violation The violation occurred as. described.

Reasons for the Violation if Admitted The requirement in the unreviewed safety question determination foi the shield plugs= to be installed was not specifically addressed in the modification instructions. This was caused by a failure of both the cognizant engineer and other plant sections to recognize this requirement and add i.t to their instructions..

Corrective Ste s Which Hay= Been Taken and Results Achieved The shield plugs were installed. and have been marked to indicate that they cannot be removed with the plant at. power.

Corrective Ste s Which Will Be Taken to Avoid Further Violations Classes have been held with modification engineering personnel to ensure that they understand the requirement to ensure that all special conditions are satisfied in the implementation of modifications. In addition, changes to administrative instructions have been initiated to provide for more complete review of modification instructions by plant sections.

Date When Full Com liance Will Be Achieved All actions have been completed, except for the. change to administrative instructions. These are being reviewed and are expected to be issued May 1, 1981.

Violation B Technical Specification 6.3.D.2 requires each high radiation area in which the inten'sity of the radiation is greater than 1,000 mrem/hr shall be provided with locked doors to prevent unauthorized entry and the keys maintained under administrative control of. the shift engineer on duty Contrary to the above, on December 22, 1980, the door to unit 3, 3A reactor cleanup pump room was not locked or guarded to prevent unauthorized entry. This room is posted as a high radiation area and a radiological survey was conducted on December 16, 1980 and the highest general .area radiation reading was 2,000 mrem/hr. '

This is a Severity Level V Violation. (Supplement I.E~) applicable to unit 3.

Admission or Denial of the Alle ed Violation The violation did occur as stated in that no one was restricting access to 3A reactor water cleanup (RWCU) pump room on a continuous .basis.

Reasons for the Violation if Admitted To gain access to the reactor water cleanup pump room, it was necessary to request access from the shift engineer on duty, who dispatches an assistant unit operator with a key to open the door. This particular task involved work in both 3A and 3B pump rooms. Both doors were opened to avoid the necessity of 1'caving the contaminated zone to contact the shift engineer a second time for entry into the second room. It was the opinion of the personnel performing the job, that since they were in. the contaminated zone which encompassed the entrance to both pump rooms, they had adequate control of access to the hi'gh radiation areas.

Corrective Ste s Which Have Been Taken and Results Achieved Personnel have been informed that .this practice is in violation of technical specifications and federal regulations. Recurrence of this incident will result in disciplinary action against tho'se involved.

Corrective Ste s Which Mill Be Taken to Avoid Further Violations Health physics personnel covering'perations on the RWCU pump rooms were.

informed by memorandum that this practice is unacceptable.

Date When Full Com liance Will Be Achieved Full compliance was achieved on Apri1 1, 1981, when a memorandum to health physics personnel was issued.

Violation C Technical Specification 6.3.A requires detailed written procedures to be prepared, approved, and adhered to. Mechanical Maintenance Instruction Number 77 requires that during the replacement of the main steam safety valve. the flange gaskets be removed and the flange surfaces, be cleaned with a stainless steel wire-%rush.

Contrary to the above, on December 19,. 1980, the main steam safety valve flange gaskets were not removed nor were the flange surfaces cleaned prior to valve installation.

This 'is a Severity Level V Violatiow (Supplement I.E.) applicable to unit 3.

Admission. or Denial'of the Alle ed Violation The violation occurred as described.

Reasons for the Violation if Admitted Mechani'cal Maintenance Instruction 77 did not have a specific signoff requiring the flange gaskets to be removed and the flange surfaces to be cleaned. However, this problem was recognized by engineering personnel during torquing of the valve and as schedule considerations allowed, the valve was disassembled, flange gaskets removed, flange cleaned, and valve reinstalled correctly. No hold. points were bypassed or safety functions compromised.

Corrective Ste s Which Have Been. Taken. and Results Achieved As noted above, the- valve was removed and installed properly.

Corrective Ste s Which Will Be Taken to Avoid Further. Violations Mechanical Maintenance Instruction 77 has been revised to- require a signoff on the removal of the flange gaskets and cleaning of. the gasket surfaces. In addition, the QA signoff verifying cleanliness on reassembly has had a note added to verify flange cleanliness on reassembly..

Date Full Gom liance Will Be Achieved Pull compliance was achieved on March 3, 1981, when Mechanical Maintenance Instruction 77" was revised.

,,Qi Violation D 10 CPR 50, Appendix B, Criterion XI implemented by Topical Report TVA-75-01, Table 17.2.3 and Operational Quality Assurance Manual, Append& B,'equires in part that test results. shall be documented and evaluated to.assure that requirements have been satisfied.. Workplan Numbers 6371 'and 7703 (which were issued to install high 'density spent fuel storage racks into units *1 and 3 spent fuel. pools) requires that:

(1) test results (conducted to assure that neutron absorbing material had been. installed) shall be evaluated and verified for acceptability and (2) the workplans are to be reviewed for completion by. Quality Assurance.

Contrary to the above, an evaluation and verification of the test results had not been performed for unit 1 fuel storage modules 2, -3, 5, 6, and 7 until December 2, 1980. Spent fuel had been loaded into fuel storage modules 2, 5, and 6 since January 1980. The workplan had not been reviewed for completion by Quality Assurance for the aforementioned fuel.

storage modules. .The workplan for. unit 3 did not have Quality Assurance review accomplished for fuel. storage module 3 and 6. Spent fuel had been loaded into fuel storage module 6 since August 1979.- The fuel storage modules were installed September 1978.

This is a Severity Level V Violation (Supplement I.E.) applicable to units-1 and 3..

Admission or Denial of the Alle ed Violations TVA admits that test results were not formally documented on unit 1 for modules in'1ocations 2, 3, 5, 6, and 7 until December 2, 1980. The test results for unit 3 storage modules in locations 3 and 6 were formally reviewed and documented by the cognizant engineering section and quality assurance section on September 8, 1978 before any fuel installation in the unit 3 modules. The final overall review by. the quality assurance section for both unit workplans had not been made.

The final overall review and quality assurance signoff of the work packages had not been made due to other minor revisions to the workplans which did not affect the overall acceptability of the module for use.

Corrective Ste s Which Have Been Taken and the Results Achieved The workplan data sheets have been formally reviewed by the cognizant sections and quality assurance personnel to ensure that all data are complete and signoffs have been made. Both workplans have been submitted for final review and closure.

Corrective Ste s'Which Will Be Taken to Avoid Further Violations This violation and its causes will be discussed with modification personnel to emphasize the requirements that all test results must be evaluated and formally documented to assure requirements have been satisfied prior to declaring a system or component ready for use.

Date When Pull Com liance Will Be Achieved The training will be completed by April 15,. 1981.