IR 05000259/1993012
| ML18037A401 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/30/1993 |
| From: | Merschoff E NRC Office of Inspection & Enforcement (IE Region II) |
| To: | Medford M Tennessee Valley Authority |
| References | |
| NUDOCS 9308060156 | |
| Download: ML18037A401 (8) | |
Text
JUN 30 tgcg
/
z Docket Nos. 50-259, 50-260, 50-296 License Nos.
DPR-33, DPR-52, DPR-68 Tennessee Valley Authority ATTN:
Dr. Mark 0. Medford, Vice President, Technical Support 3B Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Gentlemen:
SUBJECT:
REPORT NOS. 50-259/93-12, 50-260/93-12 AND 50-296/93-12 Thank you for your response of June 1,
1993, to our Notice of Violation issued on April 30, 1993, concerning activities conducted at your Browns Ferry facility.
We have evaluated your response and found that it meets the requirements of 10 CFR 2.201.
t In your response, you requested that the violation be reclassified as a
Severity Level V violation and you denied Example 2.
After careful consideration of the bases fo} your request to reclassify the violation as a Severity Level V violation, we have concluded, for the reasons presented in the enclosure to the letter, that the violation was properly classified as a Severity Level IV violation.
In addition, as discussed in the enclosure, we have concluded that Example 2 occurred as stated.
We will examine the implementation of your corrective actions during future inspections.
We appreciate your cooperation in this matter.
Sincerely, (Original signed by E. Merschoff)
Enclosure:
Evaluations and Conclusion Ellis W. Merschoff, Director Division of Reactor Projects cc w/encl:
(See page 2)
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Evans, RII P. J. Kellogg, RII S. J. Vias, RII B. Bordenick, OGC M. S. Callahan, GPA/CA T. H. Ross, NRR G. Lainas, NRR F. Hebdon, NRR Document Control Desk NRC Senior Resident Inspector U.S. Nuclear Regulatory Commission Route 12, Box 637 Athens, AL 35611 RII:
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JUN 30
[gcg Tennessee Valley Authority cc w/encl:
Mr.
W. H. Kennoy, Director Tennessee Valley Authority ET 12A 400 West Summit Hill Drive Knoxville, TN 37902 R.
M. Eytchison, Vice President Nuclear Operations Tennessee Valley Authority 3B Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Pedro Salas Site Licensing Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P. 0.
Box 2000 Decatur, AL 35602 0. J. Zeringue, Vice President Browns Ferry Operations Tennessee Valley Authority P. 0.
Box 2000 Decatur, AL 35602 B. S. Schofield, Manager Nuclear Licensing and Regulatory Affairs Tennessee Valley Authority 5B Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 TVA Representative Tennessee Valley Authority 11921 Rockville Pike Suite 402 Rockville, MD 20852 General Counsel Tennessee Valley Authority ET llH 400 West Summit Hill Drive Knoxville, TN 37902 Chairman, Limestone County Commission P. 0.
Box 188 Athens, AL 35611 C.
E. Fox, M.D.
State Department of Public Health State Office Building 434 Monroe Street Montgomery, AL 36130 Mr. Raul R. Baron Site guality Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P. 0.
Box 2000 Decatur, AL 35602 bcc w/encl:
(See page 3)
EVALUATIONS AND CONCLUSION On April 30, 1993, a Notice of Violation was issued for a violation identified during a routine NRC inspection.
The Tennessee Valley Authority (TVA)
responded to the'otice on June 1,
1993.
In the response, TVA requested that the violation be reclassified as a Severity Level V violation based on the significance of Example 1 and denied Example 2.
The NRC's evaluations and conclusion regarding the licensee's arguments are as follows:
Restatement of iolatio Technical Specification Section 6.8.1. l.a, requires that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Included in the appendix are administrative procedures covering equipment control (e.g.,
locking and tagging).
Site Standard Practice 12.3, Equipment Clearance Procedure, requires clearances involving control fuses located on multiple fused terminal boards that are required to be tagged shall have the control fuses removed, a hold notice tag attached to fuse blanks, and the fuse blanks inserted into the fuse clips.
Also required is that each hold notice shall specify the component's positional condition on the clearance sheet.
Contrary to the above, these requirements were not met for the following two examples:
l.
On March 30, 1993, the inspector identified five instances of hold order tags not in place with the clearances still active.
The inspector found five tags attached to fuse blanks lying inside a control room back pan'el cabinet while craft were working in the panels.
2.
On April 12, 1993, the inspector identified two hold order tags on clearance number 3-93-0045 that did not correctly specify the component's position/condition on the clearance sheet.
The clearance sheet specified the position of PK block covers as
"PLACED" but the block covers were removed and lying on the floor with the tag attached.
Summar of Licensee's es onse In regard to Example 1, the licensee argues that the violation was isolated in nature and was due to a small number of hold order tags being inadvertently dislodged in a congested area.
The licensee considers the significance of the five dislodged tags as minor considering that approximately 30,000 tags were placed during the outage and no additional dislodged tags were discovered in the Unit 2 control room.
The licensee states that the equipment clearance ensures the proper component configuration in addition to the tag and main-tains that the equipment was deenergized as required by the clearance.
The licensee further argues that Section 6.1.1 of the Enforcement policy provides for the classification of a violation at Severity Level V if that violation
"involves the performance of work by a craftsman resulting in a clearly minor, isolated concern."
In regard to Example 2, the licensee argues that the description used to specify the position of the P-K block covers was consistent with BFN practice, with the training provided to the operators for tagging these components and with procedures.
The licensee did take additional actions to ensure that a
system which has been tagged out is not inadvertently energized.
These actions included attaching the tag to the stationary component of the P-K blocks and revising the equipment clearance procedure.
NRC Evaluation The NRC has reviewed the licensee's response and concludes that there is not sufficient reason to reclassify the violation as a Severity Level V violation.
This decision is based on the number of examples identified by the NRC and the apparent lack of responsiveness by personnel in the control room to correct the hold order problems and ensure procedural compliance.
As to the first example, the NRC is not of the view that the five dislodged tags are of minor safety significance.
The five examples of dislodged fuse blanks and the failure of multiple individuals working in the control room back panels to notify the Shift Operations Supervisor when the fuse blanks became dislodged places this example outside the guidance of Section 6. 1. 1 of the NRC Enforcement manual.
Section 6. 1. 1 describes work by a craftsman resulting in an isolated concern.
The statement that five dislodged tags are of minor safety significance considering the 30,000 tags placed during the outage does not take into account that the tags may not have been dislodged but were intentionally removed without permission to facilitate on-going work in the panels.
If this is the case, management should recognize this may be an indicator of lack of work discipline (i.e., failure to follow procedures,'isregard for station policies, etc.)
on the part of the maintenance staff.
In this situation, the inspector identified multiple examples, easily recognized by persons working in the area.
The dislodged tags were ignored and not corrected.
With regard to Example 2, a copy of the training lesson plan and other examples of similar tagouts were requested from the licensee on June 8, 1993.
The inspector was informed on June ll, 1993, that there were no lesson plans.
After further discussions with the licensee on the tagout practices for P-K block covers, the licensee was unable to provide any additional information to support the position that the description used to specify the position of the P-K block covers was consistent with BFN practices and that this practice was covered in operator training.
Therefore, we have concluded that Example
occurred as stated.
NRC Conclusion For the above reasons, the NRC staff concludes that the violation was properly categorized as a Severity Level IV violation and that Example 2 occurred as stated.