ML18038B723

Responds to NRC 960619 Ltr Re Violations Noted in Insp Rept 50-259/96-05,50-260/96-05 & 50-296/96-05.Corrective Actions: Counseled Personnel on Mgt Expectations Re Site Specific Procedure Overtime Restrictions

ML18038B723
Person / Time
Site:	Browns Ferry
Issue date:	07/19/1996
From:	Machon R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9607240174
Download: ML18038B723 (12)

See also: IR 05000259/1996005

Text

CATEGORY 1 REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM'RZDS)

ACCESSION NBR:,9607240174

DOC.DATE: 96/07/19 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

MACHONiR.DE

Tennessee Valley Authority RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)DOCKET 05000259 05000260 05000296 SUBJECT: Responds to NRC 960619 ltr re violations

noted in insp rept 50-259/96-05,50-260/96-05

&.50-296/96-05.Corrective

actions: counseled personnel on mgt expectations

re Site Specific Procedure overtime'estrictions.

DISTRIBUTION

CODE: ZEOlD'COPIES RECEIVED:LTR

ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response NOTES: RECIPIENT ID CODE/NAME:

PD2-3-PD INTERNAL: ACRS FILE CE NRR/DRCH/HHFB

NRR/DRPM/PERB

OE DZR RGN2 FILE 01 EXTERNAL: LITCO BRYCE,J H NRC PDR COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME WILLIAMSiJ.

AEOD/SPD/RAB

DEDRO NRR/DISP/PIPB

NRR/DRPM/PECB

NUDOCS-ABSTRACT

OGC/HDS3 NOAC COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1.1 1 1 1 1 D 0 C U N NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, t ROOM OWFN 5D-5(EXT.415-2083)TO ELIMINATE YOUR NAME FROM DISTRIBUTION

LISTS FOR DOCUMENTS YOU DON'T NEED(TOTAL NUMBER OF COP1ES REQUIRED:'TTR'9

ENCL 19

k

TenneSSee Valley Autncrity.

POSt OffCe BOX 2000, DeCatur.Aabarna 35609r2000

R.D.(Rick)Machon Vice President, Browns Ferry Mucfear Ptant July 19, 1996 U.S.Nuclear Regulatory

Commission

ATTN: Document Control Desk Washington, D.C.20555 Dear Sir: 10 CFR 2 201 BROWNS FERRY NUCLEAR PLANT (BFN)-NRC INSPECTION

REPORT 50-259'0-260~

50-296/96-05

-REPLY TO NOTICE OF VIOLATION (NOV)This letter provides our reply to the subject NOV transmitted

by letter from Mark S.Lesser, NRC, to Oliver D.Kingsley, TVA, dated June 19, 1996.Th'is NOV involved a failure to implement the requirements

for overtime restrictions

during maintenance

activities

on safety-related

equipment.

TVA admits the violation.

Enclosure 1 to this letter provides TVA's"Reply to the Notice of Violation," as required'y

10 CFR 2.201.Enclosure 2 contains a commitment

made in this reply.If you have any questions.

regarding this reply, please contact Pedro Salas at (205)729-2636.Sincerely, R'.D.on Enclosures

cc: See page 2 9607240174

960719 PDR ADQCK 0500025'P 6 PDR;j ED(

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U.S.Nuclear Regulatory

Commission

Page 2 July 19, 1996 Enclosures

cc (Enclosures):

Mr..Mark S.Lesser, Branch Chief U.S.Nuclear Regulatory

Commission

Region ZZ 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Xnspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611 Mr.J.F.Williams, Project Manager U.S.Nuclear Regulatory

Commission

One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852

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ENCLOSURE 1TENNESSEE VALLEY AUTHORZTY BROWNS FERRY NUCLEAR PLANT (BFN)UNZTS Lp'2g AND 3 ZNSPECTZON

REPORT NUMBER 50-259~50-260~50-296/96-05

REPLY TO NOTZCE OF VZOLATZON (NOV).RESTATEMENT

OF VIOLATION"Technical Specification 6.8.1.1(b)

requires that written procedures

shall be established, implemented, and maintained

which limit the amount of overtime worked by individuals

performing

safety-related

functions.

Site Specific Procedure (SSP)-1.7, Overtime Restrictions (Regulatory), Revision 3, is the implementing

procedure for overtime controls.SSP-1.7 states that an employee may work no more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any, 48-hour period, or 72-hours in any 7-day time period, excluding shift turnover time, without an approved exemption.

Contrary to the above, from March 26 to March 28, 1996, written procedures

were not implemented

when Customer Group workers performed safety related functions in excess of the SSP-1.7 limitations

without approved exemptions.

During diesel generator circuit testing, a test.performer worked approximately

31.hours out of the previous 48.hours without an approved exemption.

Additionally, during March 29 to April 18, several additional

examples of workers exceeding limits without an approved exemption, were identified.

This is a Severity Level IV violation (Supplement

I)." 1.Reason For The Viol'ation

This violation resulted from a personnel error.The Customer Group (CG)Supervisor

failed to adequately

communicate

the Site Standard Practice (SSP)overtime restrictions

to CG workers for ensuring the SSP overtime requirements

were not exceeded without an approved exemption.

Specifically, on March 28, 1996., the backshift work crew was scheduled to return to dayshift.However, this shift change did not allow an adequate rest period and resulted in the backshift work crew, working 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> in a 48-hour period without obtaining an approved exemption.

Additionally, as noted in the violation, this work crew was assigned to work on.safety-related

equipment.

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'2.Corrective

Actions Taken And Results Achieved To prevent recurrence

of this event, BFN CG supervision

and personnel were.counseled on management

expectations

concerning, SSP overtime restrictions.

This counseling

session heightened

the CG personnel's

awareness of the SSP requirements, and defined their responsibility

for monitoring

their overtime individually

to ensure that an approved exemption is obtained if the SSP overtime restrictions

are to be exceeded.Also, TVA CG management

reemphasized

to the BFN CG supervisor

the need for planning, scheduling, and monitoring

employee work hours to avoid violations

of SSP overtime restrictions

and to ensure appropriate

overtime exemptions

are obtained when necessary.

To assess the extent of the condition described in the NOV, TVA performed a self-assessment

of plant staff who perform safety-related

functions as described in NRC Generic Letter 82-12,"Nuclear Power Plant Staff Working Hours." TVA's review included Operations, Engineering, Maintenance, and Radcon group's compliance

with SSP-1.7.To date, TVA's assessment

has identified

additional

examples of a failure to follow procedure in the Maintenance

group.TVA has documented

this condition in accordance

with the.corrective

action program.3'Corrective

Ste s That[Have Been Or)Will Be Taken To Avoid Further violations

TVA is performing

a review of other sections for compliance

with overtime restrictions.

Where additional

examples are identified, appropriate

corrective

actions will be taken.4~Date When Full Co liance Will Be Achieved TVA will be in full compliance

by September 18, 1996, upon the completion

of the review and implementation

of any corrective

actions.El-2

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ENCLOSURE 2 TENNESSEE VALLEY AUTHORZTY BROWNS FERRY NUCLEAR PLANT (BFN), UNITS 1~2~AND 3 INSPECTION

REPORT NUMBER 50-259'0-260'0-296/96-05

REPLY TO NOTICE OF VZOLATZON (NOV)'TVA will perform a review of other sections for compli'ance

with overtime restrictions.

Where additional

examples are identified

appropriate

corrective

actions will be taken.This review and implementation

of any corrective

actions will be complete by September 18, 1996..

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