ML18036B215

Responds to NRC Re Violations Noted in Insp Repts 50-259/93-02,50-260/93-02 & 50-296/93-02.C/As:containment Purge & SBGT Sys Evaluated & Recommendations Included in Sys Procedures for Appropriate Recurrence Control

ML18036B215
Person / Time
Site:	Browns Ferry
Issue date:	03/24/1993
From:	Zeringue O TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9303300135
Download: ML18036B215 (13)

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PgggggAX,DIgW~VTIQN,sYis' ACCESSION NBR:9303300135, DOC.DATE: 93/03/24 NOTARIZED: NO ACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee AUTH.NAME AUTHOR AFFILIATION ZERINGUE,O.J.

Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk.)

DOCKET 05000259 05000260 05000296

SUBJECT:

Responds to NRC 930225 ltr re violations noted in insp repts 50-259/93-02,50-260/93-02

& 50-296/93-02.C/As:containment purge

& SBGT sys evaluated

& recommendations included in sys procedures for appropriate recurrence control.

DISTRIBUTION CODE:

IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:

RECIPIENT ID CODE/NAME HEBDONiF WILLIAMSgJ.

INTERNAL: ACRS AEOD/DSP/TPAB DEDRO t

NRR/DRCH/HHFBPT NRR/DRSS/PEPB NRR PMAS/ILPB2 G FIL 02 RGN2 FILE 01 EXTERNAL EG&G/BRYCEiJ

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RECIPIENT ID CODE/NAME ROSS,T.

AEOD/DEIB AEOD/TTC NRR/DORS/OEAB NRR/DRIL/RPEB NRR/PMAS/ILPBl NUDOCS-ABSTRACT OGC/HDS3 RES MORISSEAU,D NRC PDR COPIES LTTR ENCL 1

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NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE IIELP US TO REDUCE WASTE! CONTACT TIIE DOCUMEN'I'ONTROLDI>V, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTlON LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 24 ENCL 24

Tennessee Valley Autttority, Post Olfice Box 2OOO. Decatur, Alabama 35609-WOO O. J. "Ike" Zeringue Vice PresldenlBrowns Perry Nuclea Pia~t MAR 34 1993 U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.C.

20555 Gentlemen:

In the Matter of Tennessee Valley Authority Docket Nos.

50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) NRC INSPECTION REPORT 50-259, 50-260, 296/93-02 REPLY TO NOTICE OF VIOLATION (NOV)

This letter provides TVA's reply to the NOV transmitted by letter from Paul J. Kellogg to M. 0. Medford dated February 25, 1993.

In the transmitted letter, NRC cited TVA with a technical specifications violation.

This violation had three examples for failure to conduct required surveillance tests.

Example 1 discussed a failure to perform the Unit 2 refueling crane prerequisite surveillance test prior to fuel movement.

Example 2 identified a missed halogenated hydrocarbon test on the Unit 2 train B CREV unit.

Example 3 characterized a foreman that missed a prerequisite signoff.

As described in the enclosures of this letter, TVA agrees that the violation occurred as stated.

Enclosure 1 provides TVA's "Reply to the Notice of Violation" (10 CFR 2.201).

280i2i 9303300i35 930324 PDR ADDCK 05000259 8

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U.S. Nuclear Regulatory Commission eR 2,4 l993 If you have any questions regarding this reply, please telephone G.

D. Pierce at (205) 729-7566.

Sincer'ely, (i'Z(((i(g(.

0 J. Zeringue

.Enclosure cc (Enclosure):

NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637

Athens, Alabama 35611 Mr. Thierry M. Ross, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North

. 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

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EHCLOSURE Tennessee Valley Authority Browns Ferry Huclear Plant (BFH)

Reply to Hotice of Violation (HOV)

Inspection Report Humber 50-25 260 2 6 93-02 RESTATEMENT OF VIOLATION "Technical Specification 6.8.1, Procedures, requires that written procedures shall be established, implemented, and maintained covering surveillance and test activities and the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February,1978.

Appendix A of Regulatory Guide 1.33 includes administrative procedures for performing maintenance.

Contrary to the above, these requirements were not met for the following three examples:

Technical Specification 4.10.D requires the Reactor Building crane operability surveillance, Surveillance Instruction 0-4.10.D, be performed prior to the handling of new fuel.

Between January 10 and January 18, 1993 new fuel was handled with the Reactor Building crane: without first performing this surveillance.

This was identified by the licensee on January 27, 1993.

2.

Site Standard Practice 6.50, Post-Maintenance

Testing, Section

'3.1.2 requires that post-maintenance testing shall be sufficiently comprehensive to ensure that corrective and/or preventive maintenance work does not adversely affect equipment operability.

On November 28,

1992, a seven day limiting condition for operation was entered,to perform maintenance on the Control Room Emergency Ventilation Unit B.

The unit was breached and internal charcoal trays removed during this maintenance activity.

Following its replacement on November 29, 1992, Surveillance Instruction 0-4.7.E.3.B was not performed as required to verify the maintenance activity did not adversely affect its operability.

This was identified by the licensee on December 30, 1992.

3.

Site Standard Practice 6.2, Maintenance Management

System, provides for the planning and performance of work orders.

This instruction was not followed when on February ll, 1993, an NRC inspector identified work being conducted on the High Pre'ssure Coolant

'Injection system using Work Order 93-00507-1 without the job pre-requisites being signed by the foreman as having been verified.

This is a Severity Level IV Violation (Supplement I) applicable to all three units."

~2 REPLY TO EXAMPLE 1 l.

Reason for Example 1

This event was a result of ambiguous or missing instructions as to who should signoff a prerequisite verification step 4.3.1 of General Operating Instruction for new fuel operations.

As a contributing factor to this event, there was a lack of formal guidance to determine the status of completed SIs.

Knowledge of whether or not an SI had been performed is not necessarily information that the refuel floor shift manager or mechanical foreman would have available.

Nevertheless, the refuel floor'shift manager signed off the step after the mechanical foreman stated that SI had been performed.

2.

Corrective Steps Taken and Results Achieved New fuel receipt and inspection activities involving use of the overhead crane to handle fuel bundles and spent fuel casks were immediately suspended.

The reactor building crane surveillance to check and inspect the overhead crane on the refuel floor was performed and successfully completed.

GOIs were revised to identify work control as the required signoff organization to verify SI completion.

Operations personnel were instructed to verify the latest performance of SIs through work control.

3.

Corrective Steps That [have been or] Will Be Taken To Prevent Recurrence No further actions are required to preclude recurrence of this violation.

4.

Date When Full Compliance Will Be Achieved TVA considers that full compliance was met when Operations personnel were instructed to verify the latest performance of SIs through work control and when the GOIs were revised on March 12, 1993.

REPLY TO EXAMPLE 2 Reason for Example 2

This event was a result of issuing the work order without sufficient details and insufficient procedural controls which allowed inappropriate removal of the charcoal adsorber tray.

This resulted in a lack of a detailed maintenance procedure for the disassembling of the CREV units.

Therefore, no disassembly or special requirements was provided in the System, Instrument Maintenance Index (SIMI).

This lack of a maintenance procedure affected both the planners and the craftsmen in the performance of their work activities.

A contributing factor to this event is that the calibration of the temperature instrument is a new preventive maintenance activity.

The SIMI documents generally provide special requirements and configuration changes involved in calibration of a component, and the SIMI document was reviewed during the preparation of the work order.

However, at the time of the activity (or event),

the referenced SIMI for this work plan did not contain any special notes or disassembly information.

Consequently, the work plan did not include sufficient instructions for disassembling the CREV unit.

As with the work order planners, the craftsmen reviewed the applicable SIMI document.

Since the SIMI document did not contain any specific configuration control information, the craftsmen also presumed that no configuration changes were required.

Consequently, the charcoal adsorber trays were removed to gain access to a temperature instrument without documenting the activity as a configuration change as required by the procedure.

2.

Corrective Steps Taken and Results Achieved Upon being informed of the condition, Operations personnel declared the CREV train B inoperable, and a seven-day limiting condition for operation (LCO) was entered.

A halogenated hydrocarbon test was initiated and satisfactorily completed after which operability of CREV train B was reestablished.

The applicable SIMI document was revised to include information on the configuration changes associated with calibrating of the temperature instrument.

Preventive maintenance task files were revised to include specific steps for disassembling of the CREV units.

Training was conducted with maintenance personnel concerning the circumstances surrounding this event.

The containment purge and standby gas treatment systems were evaluated, and recommendations were included in these system procedures for appropriate recurrence control.

Finally, procedures for performing both troubleshooting and configuration control of instruments and electrical equipment were revised.

These revisions ensure that intrusive disassembly of major plant equipment is no longer allowed without proper administrative controls.

3.

Corrective "Steps That [have been or] Will Be Taken To Prevent Recurrence No further actions are required to preclude recurrence of this violation.

4..

Date When Full Compliance Will Be Achieved TVA considers that full compliance occurred when appropriate procedures were revised on March 5, 1993.

REPLY TO EXAMPLE 3 l.

Reason For Example 3

This violation example is the result of a lack of attention to details.

Electrical maintenance personnel were disconnecting the electric operator on a motor operated valve in support of mechanical maintenance activities.

The craftsman signed off step 1.0 of the work instructions.

This signature affirmed that the craftsman reviewed and understood the precautions/limitations and work instructions.

The next step in'the work instructions (1.1) required a Foreman/Designee to sign off that the prerequisites of the instructions have been met.

However, the craftsman,did not sign off the step as the designee or obtain a foreman's signature prior to proceeding to the next step.

Contributing factors for this oversight are:

(1) In other work instructions, the step which requires a concurrence signature that the prerequisites have been met is generally the foreman's responsibility.

In the work instruction, there is no option for a designee to sign off that the prerequisites were met.

Therefore, the craftsman did not sign off step 1.1 of this work instruction as

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l the designee.

(2) Even though the individual who was the foreman for this event has received an orientation on BFN expectations for foreman activities, the foreman had just been promoted for the Unit 2 refueling outage.

Therefore, he was not fully aware of all the responsibilities of the position.

2.

Corrective Steps Taken and Results Achieved Work activities on this MOV repair were immediately suspended.

The foreman on this work activity was interviewed and subsequently the foreman resigned from the position.

A meeting was conducted with electric maintenance foremen and craftsmen to emphasize the need to pay attention to details and to emphasize work expectations during outages.

3.

Corrective Steps That [have been or] Will Be Taken To Prevent Recurrence No further actions are required to preclude recurrence of this violation.

4.

Date When Full Compliance Will Be Achieved TVA considers that full compliance was met when the individual resigned the position and after the work expectation meeting was conducted.

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