ML18031A576

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Forwards Supplemental Response to Violation Noted in Insp Repts 50-259/86-03,50-260/86-03 & 50-296/86-03.Plant Std Practice BF-14.3, Periodic Plant & Housekeeping Insps, Being Revised to Assign Group to Maintain Cleanliness
ML18031A576
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 06/27/1986
From: Gridley R
TENNESSEE VALLEY AUTHORITY
To: Grace J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8607180172
Download: ML18031A576 (8)


Text

TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 3740 I 5N 157B Lookout Place June 27, 1986 U.S. Nuclear Regulatory Commission Region II ATTN:

Dr. J.

Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

Dear Dr. Grace:

BROWNS FERRY NUCLEAR PLANT UNITS 1, 2

AND 3 NRC-OIE REGION II INSPECTION REPORT 50-259/86-03,

-260/86-03, 296/8 -03 SUPPLEMENTAL RESPONSE Please refer to my letter to you dated March 31, 1986 which provided our response to Inspection Report 86-03 for our Browns Ferry Nuclear Plant.

Enclosed is a supplemental response to the one Severity Level V violation.

If you have any questions, please get, in touch with R.

E. Rogers at FTS 858-2723.

To the best of my knowledge, I declare the statements contained herein are complete and true.

Very truly yours, TE ESSEE EY AUTHORITY Enclosure cc:

Mr. James Taylor, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.

20555 R.

ridley, Di ector Nuclear Safet and Licensing 8607180172 860627 PDR ADOCK 05000259 8

PDR An Equal Opportunity Employer

~act

SUPPLEMENTAL RESPONSE NRC INSPECTION REPORT NOS.

50-259/86-03, 50-260/86-03, AND 50-296/86-03 J.

A. OLSHINSKI'S LETTER TO S. A. WHITE DATED FEBRUARY 28, 1986 Item 1 10 CFR 50 Appendix B, Criterion V, requires in part that activities affecting quality shall be prescribed by documented instructions or procedures and accomplished in accordance with these instructions or procedures.

Browns Ferry Nuclear Plant Standard Practice No. BF-14.3 requires all assigned areas to be inspected at least once a month for housekeeping requirements and documented on a Form 96.

TVA's Standard Practice No. BF-14.36 requires aerosol cans to be stored in flammable. liquid storage cabinets or in an area away from all sources of heat and the area posted.

TVA's Liquid Penetrant Procedure No. N-PT-1 requires, in part, that after final examination, the test surface shall be cleaned with an approved cleaner.

TVA's Operational Quality Assurance Manual, Part II, Section 1.2, defines housekeeping as encompassing all activities related to control of cleanliness of facilities, cleanliness of material and equipment, fire prevention, fire protection, control of ac'cess, protection of equipment, radioactive contamination control, and storage of solid radioactive waste.

Contrary to the above instructions and -procedures, on January 14,

1986, the following discrepancies were observed in housekeeping:

a.

Anti-C clothing, clean air respirators, tape and trash on floor in Unit 2 dress out area.

b.

Trash, dirt, grinding dust, used grinding wheels and cigarette butts on floor in Unit 2 Access Room area posted as "Highly Contaminated Area,"

(condition reported to have existed for several months and also reported as deficient housekeeping

area, but no action taken to improve conditions).

c.

Trash on floor and platforms in Unit 2 drywell,:

among items observed was partial filled can of highly flammable DUBL CHEK, Cleaner/Remover 60.

d.

Penetrant material observed on 6 inch diameter reactor water cleanup system'pi,ping, a platform below where the examination had been performed on other piping.

This is a Severity Level V violation (Supplement I).

March 31 1986 Res onse l.

Admission or Denial of the Alle ed Violation TVA admits the violation.

Reason for the Violation 3.

Many activities were simultaneously being conducted in the drywell by various plant groups.

There was no group specifically designated as being responsible for overall cleanliness of the drywell and dressout area.

Corrective Ste s Which Have Been Taken and Results Achieved The drywell and dressout areas have been cleaned and housekeeping deficiencies corrected.

A responsible person has been assigned to the different areas of the reactor building to coordinate the housekeeping work until a responsible group is designed for cleanliness activities.

4.

Corrective Ste s Which Will Be Taken to Avoid Further Violations Plant Standard Practice BF-14.3, "Periodic Plant and Housekeeping Inspections,"

is being revised to assign a responsible group to maintain cleanliness during unit outages.

This group will perform inspections to identify areas deficient in cleanliness and to immediately correct conditions as needed.

Additionally. Site Director Standard Practice (SDSP) 24.2 is being originated to control access to liquid penetrant sprays and other flammable materials.

5.

Date When Full Com liance Will Be Achieved Full compliance will be achieved on-April 21,

1986, when the responsible group for cleanliness is fully functional.

SDSP 24.2 will be in place by April 21, 1986.

Su lemental Res onse 4.

Corrective Ste s Which Will Be Taken to Avoid Further Violations Plant Standard Practice BF-14.3 was deleted and incorporated into Standard Practice BF-14.2, Safety Inspections and Audits.

Standard Practice BF-14.2 designates numerous groups to maintain cleanliness at Browns Ferry and requires that periodic inspections be documented on Form BF-95.

The

groups, such as Mechanical Maintenance, Health Physics, and Building
Services, perform inspections to identify housekeeping deficiencies and to correct conditions as needed.

The groups and the specific areas they are responsible for are stipulated in Plant Standard Practice BF-14.2.

Although the plant has improved considerably in housekeeping and cleanliness improvements can still be made to obtain optimum results in housekeeping and cleanliness, inspections, and documentation of inspections.

A surveillance performed in May 1986 by our Quality Assurance Surveillance Group, at the request of the Compliance staff, identified the need for additional group or section supervisory attention to the requirements of Standard Practice BF-14.2 with regard to optimum

housekeeping and cleanliness levels and documentation of housekeeping and cleanliness inspections.

Additional training will be given to the section supervisors, and Quality Assurance Surveillances will be subsequently performed to determine if compliance with Standard practice BF-14.2 is being maintained.

5:

Date When Full Com liance Will Be Achieved Housekeeping and cleanliness is an area that requires continual attention.

The additional training of the section supervisors will be completed by July 21, 1986.

Although we anticipate full compliance by July 25, 1986, we are concerned that optimum housekeeping and cleanliness levels be maintained and. therefore, we do not anticipate presenting this item to the NRC for closure until August 25, 1986, after several Quality Assurance Surveillances have been performed.

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