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)

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. 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(

0 0 cl 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

~Ci 4 t II 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 0 Cl 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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