ML18036B215
| 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) | |
See also: IR 05000259/1993002
Text
acczz.~PgggggAX,DIgW~VTIQN, sYisŽACCESSION 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/BRYCE
i J~H~NSIC COPIES LTTR ENCL 1 1 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1-1 1 1 1 1 1 1 1 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 1 1 1'1 1 1 1 1 1 1 1 1 1 1 1.1 1 1 0 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE IIELP US TO REDUCE WASTE!CONTACT TIIE DOCUMEN'I'ONTROL
DI>V, ROOM Pl-37 (EXT.504-2065)TO ELIMINATE YOUR 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'PDR~(p0
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
s
,)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'I
(.
'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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