ML18033B021
| ML18033B021 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/01/1989 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8911080281 | |
| Download: ML18033B021 (11) | |
Text
SUBJECT:
Responds to NRC 891002 ltr re violations noted in Insp Repts 50-259/89-38,50-260/89-38
& 50-296/89-38.
DZSTRZBUTZON CODE:
ZEOZD COPZES RECEZVED:LTRj ENCL $
SZZE: 7 TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response D
8 05000259 05000260 h.
05000296 NOTES:1 Copy each to: B.Wilson,D.M.Crutchfield,B.D.Liaw,S.Black R.Pierson, 1 Copy each to: S.Black,D.M.Crutchfield,B.D.Liaw, R.Pierson,B.Wilson 1 Copy each to:
S. Black,D.M.Crutchfield,B.D.Liaw, R.Pierson,B.Wilson ACCELZRATED DIS'1'MBUTION DEMONSTRATION SYSTEM
,I REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:8911080281 DOC.DATE: 89/ll/Ol NOTARIZED: NO DOCKET 4
- ACIL
- 50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 1
50-296 Browns Ferry Nuclear Power Station, Unit 3< Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION MEDFORD,M.O.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
R RECIPIENT ID CODE/NAME PD NTERNAL: ACRS AEOD/DEIIB DEDRO NRR/DEST DIR NRR/DOEA DIR 11 NRR/DREP/RPB 10 NRR/PMAS/ILRB12 EMIEBE N,J REG WF, LE 02 RGN2 FILE 01 EXTERNAL: LPDR NSIC NOTES:
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5 RECIPIENT ID CODE/NAME GEARS I G AEOD AEOD/TPAD NRR SHANKMAN,S NRR/DLPQ/PEB NRR/DREP/EPB 10 NRR/DRIS/DIR NUDOCS-ABSTRACT OGC/HDS2 RES MORISSEAU,D NRC PDR COPIES LTTR ENCL 1
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LTTR 31 ENCL 31
~l'e TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 5N 157B Lookout Place NDV iiI 1988 U.S.
Nuclear Regulatory Commission ATTN:
Document Control Desk Hashington, D.C.
20555 Gentlemen:
In the Matter of Tennessee Val'ley Authority Docket Nos.
50-259 50-260 50-296 BROHNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 -
NRC INSPECTION REPORT NOS. 50-259/89-38, 50-260/89-38, AND 50-296/89-38
RESPONSE
TO NOTICE OF VIOLATION This letter provides TVA's,response to the notice of violation transmitted by letter from B. A. Hilson to 0.
D. Kingsley, Jr.,
dated October 2, 1989.
This violation was'ited for the failure to conduct postmaintenance testing.
TVA admits the violation and views this event as an example of personnel error t
stemming from the lack of correct operational focus at BFN.
TVA management met with NRC Region II personnel on September 28, 1989, to discuss programmatic corrective actions that are being taken in order to resolve work ethic problems.
Enclosure 1 provides background information and TVA's response to the violation in the subject report.
Corrective actions will be performed by December 15,
- 1989, and are listed on Enclosure 2.
If you have any questions, please telephone Patrick P. Carier at (205) 729/3570.
Very truly yours, TENNESSEE VALLEY AUTHORITY Mark O.
Medfo d, Vice President and Nuclear Technical Director Enclosures cc:
See page 2
t 8911080281 891101 PDR ADQCH,.05000259 8
PNU An Equal Opportunity Employer
U.S.
Nuclear Regulatory Commission NOV 01 1989 cc (Enclosures):
Ms.
S.
C. Black, Assistant Director for Projects 7VA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Assistant Director for Inspection Programs TVA Projects Division U.S.
Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637
- Athens, Alabama 35609-2000
ENCLOSURE 1
RESPONSE
NRC INSPECTION REPORT NOS. 50-259/89-38, 50-260/89-38, AND 50-296/89-38 LETTER FROM B. A.
WILSON TO 0.
D.
KINGSLEY, JR.
DATED OCTOBER 2, 1989 Violation Technical Specification section 6.8.l.l.c requires that written procedures be established, implemented, and maintained covering test activities for safety related equipment.
Site Director Standard Practice 2.1, Site Procedures and Instructions, requires that the site be operated and maintained in accordance with written, approved procedures and instructions which have been formally issued and distributed for use.
Plant Manager Instruction 6.2, Conduct of Maintenance, requires that
'postmaintenance testing (PMT) be performed on all plant process equipment following all corrective maintenance activities.
Contrary to the above, following the performance of scheduled maintenance, established procedures were not properly implemented in the following examples:
a.
The required PMT designated on the maintenance request (MR) was not performed following scheduled maintenance on the
" "." Diesel Generator (DG) autostart lockout relay on August 4, 1989.
The "3C" DG was subsequently declared operable without performance of the PMT.
The required PMT was not performed following scheduled maintenance on the "D2" Residual Heat Removal Service Water (RHRSW) pump on August 16,
- 1989, and on the "D3" RHRSW pump on September 1,
1989.
In both cases the PMT designated in the MR was not accomplished prior to returning the applicable components to service.
TVA's Res onse
~Exam le a:
l.
Admission or Denial of the Alle ed Violation TVA admits the violation as stated.
2.
Reasons For Violation This violation is the result of personnel error.
On August 28,
The MR requires steps 8.4.1.1 and 8.4.1.2 of EMI 100 to be performed as part of the PMT.
- However, the craftsman incorrectly signed as having completed the PMT.
U.S. Nuclear Regulatory Commission During a scheduled outage on the diesels, the autostart lockout relay on the 3C DG was removed for maintenance.
The maintenance consisted of removing the relay from the 4160 shutdown board, calibrating it, and replacing it into the shutdown board.
MR 893300 required postmaintenance testing be done when the relay was reinstalled.
The craftsman who performed the task incorrectly signed the MR as having completed the PMT, even though the attached procedure indicated that no PMT was performed.
The foreman is required to review the MR package before returning the completed MR to Work Control.
He noted the PMT block on the MR signed off but did not review the package to verify that the PMT was done.
An engineer performing the cognizant review noted that the PMT signoffs were incomplete, placed the MR in "Q" status (indicating there was a documentation error),
and notified sup'ervision.
Corrective Ste s Which Have Been Taken and Results Achieved Immediate disciplinary action was taken against the craftman and foreman including counseling, written warnings, removal from supervisory position and suspensions without pay.
The Maintenance staff was made aware of the circumstances and the significance of the incident.
The review process within maintenance has been expanded to require the general foreman to review the work packages prior to assignment to crews, field verification of field activities, verification of task completion and a personal review and verification of work package completeness and compliance with procedures.
In order to assess the programmatic impact of this event, all MRs awaiting closure were reviewed for PMT discrepancies, with none noted.
In addition, approximately 40 MRs previously placed in history were retrieved and reviewed for missed PMTs, with none found.
Corrective Ste s Which Will Be Taken To Avoid Further Violations (or
~Findln s)
No further corrective actions are required.
Date When Full Com liance Will Be Achieved Full compliance has been achieved.
~Exam le b:
Admission or Denial of the Alle ed Violation TVA admits the violation as stated.
U.S. Nuclear Regulatory Commission 2.
Reasons for Violation This violation is the result of personnel error.
The D2 and D3 RHRSW pumps were returned to service before the required PMTs were performed due to personnel error.
The MRs required the supply breaker be opened and the control power fuses removed.
The work performed by the MR replaced the 0-Rings in a relay associated with the alarm function.
Each incident of the failure to perform the PMT is depicted below:
D2 RHRSW PUMP:
The craftsman incorrectly signed off on the attachment to the MR that the PMT had been done.
The foreman then signed off on the hold order which releases the equipment for service, and turned the MR into Work Control.
Systems evaluators added the MR to the system return-to-service punchlist for RHRSW (23) and 4Kv shutdown boards and buses (211) systems.
- However, based on the initial determination in the impact evaluation that this work did not affect operability, the pump was returned to service.
D3 RHRSW PUMP:
The craftman incorrectly signed the MR as having completed the PMT The craftsman notified the foreman that the job was complete, including the PMT.
The foreman then signed the MR without verification that the work was complete.
However, it was discovered that the PMT could not have been done at this time due to a hold tag on the equipment.
Corrective Ste s Which Have Been Taken and Results Achieved Immediate disciplinary action was taken against the craftman and the foreman involved including counseling, written warning, removal from supervisory position and suspensions without pay.
TVA notes that the craftman involved in this event is the same individual who was foreman in example a above.
Consequently, TVA took progressive personnel action against that individual.
Management has made Maintenance and Operations personnel aware of the circumstances and significance of these incidents.
All MRs awaiting closure and approximately 40 of the MRs in history were reviewed for missed PMTs, with none noted.
A third level of review has been added.
The general foreman now reviews the MR packages for completion.
'e U.S. Nuclear Regulatory Commission Operations personnel are now included as part of the review process to ensure an adequate program is in place to verify that the postmaintenance/modification testing has been completed before returning equipment to service.
4.
Corrective Ste s Which Hill Be Taken To Avoid Further Violations (or
~Flndin s>
This problem as well as previous problems with the return-to-service punchlist has prompted action to incorporate it with the limiting condition for operation tra'cking system.
This should provide additional oversight by the on-shift operators and the shift technical advisors and will result in one tracking system for all return-to-service items for technical specification equipments 5.
Date Hhen Full Com liance Hill Be Achieved Full compliance will be achieved by December 15, 1989.
0
ENCLOSURE 2
RESPONSE
NRC INSPECTION REPORT NOS. 50-259/89-38, 50-260/89-38, AND 50-296/89-38 LETTER FROM B. A. NILSON TO O.
D.
KINGSLEY, JR.
DATED October 2, 1989 LIST OF COMMITMENT This problem as well as previous problems with the return-to-service punchlist has prompted action to incorporate it with the limiting condition for operation tracking system.
This should provide additional oversight by the on-shift operators and the shift technical advisors and will result in one tracking system for all return-to-service items for technical specification equipment.
Full compliance will be achieved by December 15, 1989.
l 0