ML18033B243
| ML18033B243 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/02/1990 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9004100097 | |
| Download: ML18033B243 (25) | |
Text
ACCELERATED DISTRIBUTION DEMONST$&TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ESSION NBR:9004100097 DOC.DATE: 90/04/02 NOTARIZED:
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ACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 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)
SUBJECT:
Responds to NRC 900302 ltr re violations noted in Insp Repts 50-259/89-43,50-260/89-43 6 50-296/89-43.
DISTRIBUTION CODE:
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TITLE: TVA Facilities Routine Correspondence R
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TENNESSEE VALLEYAUTHORITY CHATTANOOGA, TENNESSEE 37401 6N 38A Lookout Place APR 02 1980 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 0
BROWNS FERRY NUCLEAR PLANT (BFN) NRC INSPECTION REPORT NOS. 50-259/89-43, 50-260/89-43, AND 50-296/89-43
RESPONSE
TO NOTICE OF VIOLATION This letter provides TVA's response to the notice of violation transmitted by letter from D.
M. Crutchfield to 0.
D. Kingsley, Jr.
dated March 2, 1990.
NRC cited TVA with three violations regarding the technical specification (TS) surveillance program at BFN.
TVA admits these violations and has taken appropriate steps that address these violations.
Enclosure 1 contains TVA's response to the notice of violation.
Each violation is discussed individually with the correcti,ve.,s:teps
.taken.for each example.
TVA has taken additional corrective steps as a result of the recognized problems with the surveillance program at BFN.
Various actions have been taken to improve personnel accountability and adherence to the surveillance test program requirements.
This has resulted in a significant improvement of BFN's overall performance as evidenced by the resulting reduction in surveillance testing problems.
These programmatic actions have been taken in addition to the specific steps taken for each violation in order to address the overall problem with the TS surveillance program.
A discussion of these actions has been included as Enclosure 2.
The details of these actions have been discussed previously with NRC during meetings on September 28,
- 1989, November 21, 1989 (Enforcement Conference),
and February 9,
1990.
- Also, as requested by the letter accompanying the Notice of Violation, the actions taken to improve the communication between the surveillance, maintenance, engineering, and operations staffs has been included in the response as Enclosure 3.
Emphasis at BFN has been placed on properly identifying t>i correct root cause of an event to ensure that personnel errors are not blame'd on procedure deficiencies.
TVA considers that significant progress has been made and that additional progress will be continued.
TVA has taken adequate corrective actions to ensure continued improvement in the procedure program at BFN.
These actions are resulting in the right operational mentality to stop work if a procedure is unclear, the need to take the time to do the job right, and thorough reviews of events to determine the root cause of events.
0 I
OCK 0~~000259 100097 900402 PDR
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An Equal Opportunity Empioyer
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0 ENCLOSURE 1
RESPONSE
BROWNS FERRY NUCLEAR PLANT (BFN)
NRC INSPECTION REPORT NOS. 50-259/89-43, 50-260/89-43, AND 50-296/89-43 LETTER FROM D.
M. CRUTCHFIELD TO 0.
D. KINGSLEY, JR.
DATED MARCH 2, 1990 Violation A Technical Specification (TS) 6.8.1, Procedures, requires in part, that written procedures be established, implemented and maintained covering surveillance and test activities of safety-related systems.
Contrary to the above, l.
On August 15,
- 1989, the licensee failed to adequately establish and implement surveillance procedure O-SI-4.2.B-67, Residual Heat Removal (RHR) Service Water Initiation Logic.
Specifically, the surveillance test was inadequate in that 1't jumpered out the automatic initiation logic for all Emergency Equipment Cooling Water (EECW). pumps.
This was inappropriate to the circumstances because all eight of the Emergency Diesel Generators, as well as other safety-related equipment that require automatic initiation of EECW cooling water to function, were rendered inoperable.
2.
On December 9,
1988, during performance of 2-SI-4.28-45A (I),
RHR Logic System Functional
- Test, the operator failed to follow the procedure step requiring depression of the local manual stop button and instead, depressed the pump start button.
This resulted in the startup of the 2D RHR pump.
3.
On December 17, 1988, during the performance of O-SI-4.9.A.l.b-l, Unit 1/2 DG A Load Acceptance
- Test, the operator failed to follow the correct sequence of steps in the procedure.
Steps which initiate the pump start logic were performed prior to steps intended to block the automatic start signal.
This resulted in the startup of the 2D RHR pump.
4.
On December 18, 1988, during the performance of O-SI-4.9.A.l.b-2, Unit 1/2 DG B Emergency Load Acceptance
- Test, the operator placed the wrong keylock switch in the test position.
This resulted in the startup of'he 2C Core Spray pump during subsequent steps in the procedure.
TVA's Res onse The four examples cited above have been reported to NRC in accordance with 10 CFR 50.73, Licensee Event Reports (LER).
Th reasons for these events and the corrective steps taken are addressed individually below.
Admission or Denial of the Violation 41J 4w
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Reason For the Violation This violation has been attributed to a deficient Surveillance Instruction (SI) revised in 1976 to require the disabling of the automatic start feature of the EECW pumps during performance of the SI.
With the EECW pumps inoperable, equipment served by the EECW pumps, such as the diesel generators (DGs), would also be inoperable.
An additional cause of the event is that, between 1976 and
- 1989, licensed personnel did not question the SI instruction to disable the auto-start feature of the EECW pumps and did not identify that the SI instruction resulted in an unanalyzed condition.
This event was reported to NRC in accordance with 10 CFR 50.73 by LER 50-259/89-023-00.
Corrective Ste s Which Have Been Taken and Results Achieved The SI involved in this 'bvent was initially put on administrative hold and has since been revised to prevent removal oC all eight EECW pumps from service at the same time.
Additionally, a cross-discipline procedure review group (PRG) was created which reviewed a sample of BFN SIs to ensure that this type problem did not exist with other SIs.
The PRG consisted of representatives from Technical Support, Operations, Maintenance, and Plant Support.
This review was performed to ensure that entry into limiting condition for operations (LCOs) or initiation of conditional SIs are clearly identified to the user,.
and to ensure that SIs with actions that render
- systems, subsystems, trains, part of or all of the system logic inoperable are clear in this regard and specify allowable time intervals, time recording, and address the appropriate LCO if time limits are exceeded.
One SI was identified that contained a potential problem in that it did not specifically prevent or caution against making multiple diesel generators inoperable.
Since a potential problem was identified from the sample of SIs, all SIs were review d by the cognizant sections to identify any additional problems.
No additional SIs were identified that would result in the inoperability of equipment in violation of TS.
To reduce the probability of this type of error from occurring in the future, several additional actions have been taken.
The procedure verification review checklist procedure has been revised to add questions to identify whether a test procedure would prevent a system or device from performing its intended safety function in violation of the TS.
The procedure writers guide and procedure review procedure have been revised to require that SIs provide a statement that identifies the status of equipment operability when the Shift Operations Supervisor's permission to perform the SI is obtained.
Also, qualified reviewers have been given a
description of this event for required reading.
U.S. Nuclear Regulatory Commission APR 02 1980 If you have any questions regarding this response, please telephone Patrick P. Carier at (205) 729-3570.
Very truly yours, TENNESSEE VALLEY AUTHORITY Enclosures cc (Enclosures):
Ms.
S.
C. Black, Assistant Director for Projects TVA Projects Division U.S.
Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockvi lie, 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 Mark O. Medford
'ice President, Nuclear Technology and Licensing
Q
3.
To correct for the fact that no concerns with the SI were raised by licensed personnel, a copy of this LER and related correspondence was provided to licensed operations personnel as required reading.
Operations management will discuss with licensed personnel the need to develop and maintain a questioning attitude in performing their duties.
Emphasis wi 11 be placed on a more comprehensive review by on-shift personnel of activities requiring unusual equipment lineup or temporary alterations.
Corrective Ste s Which Will Be Taken To Avoid Further Violations To reduce the probability of further violations, several corrective actions have been taken as a result of the overall problem with the TS surveillance program in addition to the specific steps taken for this event.
These additional actions are included as Enclosure 2.
4.
Oate When Full Com liance Will Be Achieved Full compliance has beers'chieved.
~Exam le 2
Reason For the Violation 2.
This violation has been attributed to personnel error.
While performing step 7.4.20 of 2-SI-4.2.B-45A(I), the assistant unit operator (AUO) assisting in the performance of the SI incorrectly depressed the pump start button instead of the pump stop button.
This caused the 2D RHR pump to start.
The unit operator (UO) tripped the pump immediately from the control room.
The pump operated for approximately five seconds and the discharge pressure increased less than 20 psi.
Contributing to this event was the fact that the local pump start and stop buttons were not individually labeled as START and STOP.,
- However, the buttons followed normal plant conventions having the black start button on top with the red stop button below.
This event was reported to NRC in accordance with 10 CFR 50.73 by LER 50-260/88-016-01.
Corrective Ste s Which Have Been Taken and Results Achieved As a result of this event, this LER has been included in the required reading package for all licensed personnel.
Additionally, the labeling for the local RHR pump start/stop buttons has been added.
In addition to labeling the local RHR pump start/stop
- buttons, walkdowns of Unit 2 emergency core cooling systems (High Pressure Coolant Injection [HPCIl, Residual Heat Removal
[RHRj, RHRSW, Core Spray
[CS3, and EECN Systems) were performed to identify any additional labeling problems with local switches.
The discrepancies identified by this review have been corrected.
As a result of these corrective actions, this event has been closed by NRC in the Inspection Report numbered 50-259/89-50, 50-260/89-50, and 50-296/89-50 for Unit 2.
3.
Corrective Ste s Which Will Be Taken to Avoid Further Violations Walkdowns of the Unit 1
and 3 emergency core cooling systems (HPCI,
- RHR, RHRSW, CS, and EECW) will be performed and labeling discrepancies identified will be corrected before the restart of each respective unit.
This action is being tracked as a commitment to LER 50-260/88-016-01.
To reduce the probability of further violations, several corrective actions have been taken as a result of the overall problem with the TS surveillance program in addition to the specific steps taken for this event.
These additional actions are included as Enclosure 2.
4.
Date When Full Com liance Will Be Achieved Full compliance has been achieved for Unit 2 and full compliance for Units 1 and 3 will be achieved before the restart of those units.
~Exam le 3
Reason For the Violation 2.
This violation has been attributed to an inadequate procedure.
TVAs understanding of the event differs from the description contained in the notice of violation.
On December 17, 1988, during the performance of the DG A load acceptance SI, a jumper was installed to simulate a high drywell pressure coincident with a low reactor water level.
As a result of this
- signal, the 2D RHR pump automatically started.
This step was out of sequence in the SI.
The following SI step would have installed a jumper to prevent the automatic start of the RHR pump.
Contrary to the description in the notice of violation, the operator performing the SI did correctly follow the steps as written in the SI.
- However, the SI was incorrectly written in that the step to prevent the automatic RHR pump start followed the step to simulate the automatic start.
This event occurred during the first performance of a new SI.
This SI was written as a part of a revision which included making the diesel generator load acceptance SIs unit specific.
This event was reported to NRC in accordance with 10 CFR 50.73 by LER 50-259/88-049-00.
Corrective Ste s Which Have Been Taken and Results Achieved As a result of this event, the DG load acceptance SI was revis<<J to correct this deficiency.
Additionally, the procedures governing technical review and approval of procedures, the restart test program, the postmodification test program, and the conduct of testing were revised to include a caution on engineering safety feature (ESF) actuations.
As a result of these corrective actions, this event has been closed by NRC in the Inspection Report numbered 50-259/89-50, 50-260/89-50, and 50-296/89-50.
3.
Corrective Ste s Which Hill Be Taken to Avoid Further Violations To reduce the probability of further violations, several corrective actions have been taken as a result of the overall problem with the TS surveillance program in addition to the specific steps taken for this event.
These additional actions are included as Enclosure 2.
4, Date When Full Com liance Hill Be Achieved Full compliance has been achieved.
~Exam le 4
Reason For The Violation 4 ~
This violation has been attributed to personal error.
While performing SI 4.9.A.l.b-2, the opeF'ator mistakenly placed the wrong keylock test switch in the test position.
When the step-to simulate an automatic start was performed, Core Spray pump 2C started.
Also contributing to this event was the failure of the SI to require independent verification for the placement of the correct keylock switch to the test position.
This event was reported to NRC in accordance with 10 CFR 50.73 by LER 50-260/88-017-00.
2.
Corrective Ste s Which Have Been Taken and Results; Achieved As a result of this event, the operator involved received special counseling on adhering strict attention to detail, especially when performing tasks involving ESF components.
Also, the SI was revised to include independent verification of the test switch position.
As a result of these corrective actions, this event has been closed by NRC in the Inspection Report numbered 50-259/89-48, 50-260/89-48, and 50-296/89-48.
3.
Corrective Ste s Which Hill Be Taken to Avoid Further Violations To reduce the probability of further violations, several corrective actions have been taken as a result of the overall problem with the TS surveillance program in addition to the specific steps taken for this event.
These additional actions are included as Enclosure 2.
4.
Date When Full Com liance Hill Be Achieved Full compliance has been achieved.
Violation B Technical Specification 4.9.A.l.e requires that a sample of diesel fuel be t
checked for quality once a month.
0
Contrary to the above, from June 6 until September 12,
- 1989, the licensee failed to check the quality of the diesel fuel in all storage tanks once per month.
Procedure O-SI-4.9.A.l.e, "Diesel Generator Fuel Oil Analysis," which was reviewed and validated on June 6,
1989 in accordance with Site Director Standard Practice 7.4 was deficient in that it required only one of the four sets of seven-day storage tanks to be sample checked each month on a staggered basis.
Consequently, each tank was sampled only once per four months.
TVA's Res onse l.
Admission or Denial of the Violation TVA admits the violation as cited.
2.
Reason For the Violation This violation has been attributed to ambiguous TS requirements which resulted in an incorrect TS interpretation.
TS surveillance requirement 4.9.A.l.e requires once a month-sampling of diesel fuel to be checked for quality.
SI 4.9.A. l.e implemented this surveillance requirement by sampling one of the Units 1
and 2 and one of the Unit 3 seven-day storage tanks on a staggered basis.
-Therefore, each tank was sampled once per every four months.
A review of this event determined that this SI did not comply with the requirements of TS 4.9.A.l.e.
This event was reported to NRC in accordance with 10 CFR 50.73 by LER 50-259/89-026-00.
3.
Corrective Ste s Which Have Been Taken and Results Achieved As a result of this event, the SI has been revised to require monthly sampling of all DG seven-day tanks.
All chemistry SIs were reviewed for incorrect or nonconservative interpretation of surveillance requirement frequencies.
All were found to comply with the intent of the TS surveillance frequencies.
It was identi'fied that th'e sampling frequency required by TS 4.9.A.l.e was excessive relative to the Standardized Technical Specifications (STS).
Accordingly, a
TS change has been submitted consistent with STS to required sampling of each DG seven-day fuel oil tank on a quarterly basis.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations To reduce the probability of further violations, additional corrective actions have been taken as a result of the overall problem with the TS surveillance program in addition to the specific steps taken for this event.
These additional actions are included as Enclosure 2.
5.
Date When Full Com liance Will Be Achieved Full compliance has been achieved.
o
Violation C Technical Specification 3.11.E.l.a requires, in part, that with one or more of the fire hose stations shown in Table 3.11.C inoperable, provide a gated wye on the nearest operable hose station, with one outlet connected to a length of hose sufficient to provide coverage for the area left unprotected by the inoperable hose station.
Contrary to the above, on September 19,
- 1989, the gated wye and associated length of hose installed at 565 U-R9 (2-26-861) on June 28, 1989, to provide coverage for the areas left unprotected by inoperable hose stations 565 U-R13 (2-26-878) and 541 P-R14 (2-26-877) referenced in Table 3.11.C, were missing.
TVA's Res onse 1.
Admission or Oenial of the Violation TVA admits the violation"as cited.
2.
Reason For the Violation This violation has been attributed to personnel error and a lack of process control.
For one or more inoperable hose stations, TS 3.11.E requires that a gated wye be installed on the nearest operable hose station.
An additional length of fire hose sufficient to provide coverage for the area left unprotected by the inoperable hose station(s) is connected to the other side of the wye and a sign(s) is to be placed above the gated wye to indicate the proper hose to use in the event of a fire.
Fire hose station 2-26-281 was simultaneously providing compensatory measures for two different inoperable hose stations.
Between August 17, and August 28,
- 1989, an unknown person removed the sign for one of these compensatory measures.
Therefore, when the other compensatory measure was
- removed, the gated wye, additional fire hose, and compensatory sign was removed leaving the remaining inoperable fire hose station without the required compensatory measures.
This event was reported to NRC in accordance with 10 CFR 50.73 by LER 50-260/89-025-00.
3.
Corrective Ste s Hhich Have Been Taken and Results Achieved The immediate steps taken to correct the deficiency were to reestablish the required compensatory measures for the inoperable fire hose station.
Fire protection line management has reviewed a description of this event with fire protection personnel and emphasized work ethic standards and the use of progressive personnel disciplinary actions.
Personnel disciplinary actions were not taken in this instance since the individual responsible for this event was not identified.
However, in order to reduce the probability of this event recurring, fire protection procedures have been enhanced to require a periodic verification that fire protection compensatory measures are in place.
As a result of these corrective actions, this event has been closed by NRC in the Inspection Report numbered 50-259/89-50, 50-260/89-50, and 50-296/89-50.
Additionally, since this event, the site fire protection organization has been strengthened by realigning the fire protection department.
Program implementation and administrative control now falls under the Operations section.
This includes reassigning the emergency response and program administrative staff to the Operations section.
4.
Corrective Ste s Which Hill Be Taken to Avoid Further Violations To reduce the probability of further violations, several corrective actions have been taken as a result of the overall problem with the TS surveillance program in addition to the specific steps taken for this event.
These additional actions are included as Enclosure 2.
5.
Date When Full Com liance Hill Be Achieved Full compliance has been achieved.
ENCLOSURE 2
RESPONSE
BRONNS FERRY NUCLEAR PLANT (BFN)
NRC INSPECTION REPORT NOS. 50-259/89-43, 50-260/89-43, AND 50-296/89-43 LETTER FROM D.
M.
CRUTCHFIELD TO 0.
D.
KINGSLEY, JR.
DATED MARCH 2, 1990 PROGRAMMATIC ACTIONS FOR IMPROVEMENT TO THE SURVEILLANCE PROGRAM AT BFN Numerous corrective actions are being taken by TVA as a result of the recognized problems with the surveillance program at BFN.
These corrective actions include several steps which have been taken to improve personnel accountability and adherence to the surveillance test program requirements.
These actions have resulted in a significant improvement of BFN's overall performance as evidenced by the resulting reduction in surveillance testing problems.
The details of the identified problems and the corrective actions which have been implemented have been discussed previously with NRC during meetings on September 28,
- 1989, November 21, 1989 (Enforcement Conference),
and February 9,
1990.
A discussion of these items is presented below to supplement the response to the notice of violation.
These items address those overall generic actions which have been implemented in addition to the specific corrective actions taken for each of the examples in Enclosure l.
TVA has previously assessed the procedures upgrade program at BFN and identified three problem areas.
These areas involve technical
- content, programmatic
- issues, and implementation.
As a result of the actions taken to improve the program, TVA considers that technical content and programmatic issues are now adequate.
- However, problems have existed which have prevented the proper implementation of the processes.
TVA has determined that these implementation problems stem from a lack of correct operational mentality.
Several corrective actions are being implemented which are directed at improving this nuclear work ethics problem at BFN.
Each of the three identified problem areas are discussed below.
Technical Content In order to ensure the technical adequacy of surveillance procedures at
- BFN, a verification/validation (V/V) process has been implemented and the review/approval process has been strengthened.
The V/V process has combined BFN review requirements and INPO good practice guidelines into one comprehensive checklist.
This process also added a validation checklist which is used after the procedure was approved.
Validation is performed during the first use of the procedure or use on the simulator or during a walkdown.
This V/V process is applicable to man-machine interface procedures including operating procedures, surveillance instructions, and test instructions.
The requirement to validate the procedure at each operation mode applicable
=was included.
This validation process reinforces user involvement, improves quality by validating actual man-machine procedure
- use, identifies field problems, and promotes teamwork between users and technical groups.
Pro rammatic Issues Problems with programmatic issues have been addressed by several improvements to the programs/procedures governing the implementation and control of procedures and work at BFN.
Program improvements have included a restriction on the use of nonintent changes (NIC).
The procedure governing the use of NICs has been revised to change the criteria under which a NIC can be used.
This has resulted in a substantial decrease in the number of NICs implemented.
The number of NICs has decreased from more than 250 per month in July and August 1989 to less than
'15 in January 1990.
Preapproval walkdowns and walkdowns by the cognizant/system engineer with the procedure implementor have been included in the procedure governing procedure reviews.
This program enhancement will ensure ongoing improvements in procedures being used at BFN.
Also, the program for the incident investigation process has been significantly strengthened.
This change has implemented a lower threshold for the initiation of an incident investigation and the use of an immediate response team when needed.
This program improvement will ensure thorough reviews of events to determine correct root causes.
Additional program improvements are being made in the areas of surveillance scheduling, utilization of the Institute of Nuclear Power Operation's (INPO)
HPES program, equipment removal and return to service, and conduct of surveillance procedure.
The conduct of surveillance procedure improvements include the qualification of craft, responsibilities of cognizant/system engineer test director, preapproval walkdown by cognizant/system engineer and qualified performer, and validation performance prior to official performance.
Additionally, special reviews have taken'lace to ensure the adequacy of the procedures program.
Two technical reviews have been conducted.
One to verify that SIs meet technical specification (TS) frequency.
Another identified equipment out-of-service conditions.
No additional items of noncompliance with TS requirements were identified.
Also, event analysis reviews have been conducted by~lant staff, by independent safety engineering, and by INPO.
Management attention and involvement in the TS surveillance program has been increased and several corrective actions have been implemented to ensure improvement in this area.
- First, TVA has set requirements for management involvement in field observations, in documentation, and feedback of the results.
TVA has also mandated management involvement in the V/V process.
The responsible supervisor for each surveillance procedure must review the validation results and ensures that identified deficiencies have been incorporated into the surveillance procedure by a revision.
Im lementation In order to improve the work ethic standards at BFN, four corrective action steps have been set in place.
The first involves setting expectations of strict procedure compliance with a goal of zero personnel error events.
This phase has been initiated through a series of Plant Manager's talks with plant employee groups.
- Second, impediments to proper implementation are being defined and corrected.
Next, the work ethic standards are being reinforced through superintendent meetings to discuss performance and to critique events with the results posted in the work placebo
- Finally, BFN has personnel corrective action implemented through progressive disciplinary action and a review of performance problems by an error review committee.
On February 9,
During this meeting an assessment of the improving trend regarding the procedure program was presented.
An improving trend in the number of Licer5ee Event Reports, Condition Adverse to Quality
- Reports, Radiological Incident Reports, and NonLntent Procedure Changes has occurred in recent months.
These improving trends are a direct reflection of the corrective actions taken at BFN.
Emphasis has been placed on properly identifying the correct root cause of an event to ensure that personnel errors are not blamed on procedure deficiencies.
TVA considers that significant progress has been made and that additional progress can be continued.
TVA has taken adequate corrective actions to ensure continued improvement in the procedure program at BFN.
These actions have resulted in the right operational mentality to stop work if a procedure is unclear, the need to take the timo to do the job right, and thorough reviews of events to determine the root cause.
ENCLOSURE 3
RESPONSE
BROWNS FERRY NUCLEAR PLANT (BFN)
NRC INSPECTION REPORT NOS. 50-259/89-43, 50-260/89-43, AND 50-296/89-43 LETTER FROM D.
M. CRUTCHFIELD TO O.
D.
KINGSLEY, JR.
DATED MARCH 2, 1990 CORRECTIVE ACTIONS TO IMPROVE COMMUNICATIONS BETWEEN DEPARTMENT STAFFS In order to improve the communication between department staffs, several corrective steps are in place.
Currently, representatives from Work Control, Operations, Maintenance, and Technical Support attend the Operations shift turnover meetings.
Following the discussion of operations status and shift
- orders, the Outage/Work Control Shift Manager reviews the major evolutions that are in progress or scheduled to start during the upcoming shift along with any special coordination or support requirements.
Procedures on the conduct of testing require Test Directors to conduct a
briefing with all involved Pest personnel prior to the commencement of the test and each shift thereafter.
For less involve 1 tests, Lead Performers conduct pretest briefings whenever the test is expected to extend beyond one shift duration or if active coordination of two (2) or more organizations is required.
In addition, the following communications are required between the performing organization and operations on any test or plant activity involving physical work:
o Shift Operations Supervisor (SOS) notified prior to initiation and at the completion of a test and of the results.
o The Unit Operator (UO) is notified prior to the performance of any activity on equipment affecting unit operation or safety and of expected parameters when the possibility of abnormal conditions exist.
T o
The SOS and Shift Technical Advisor (STA) are notified immediately of any condition that resulted in or could result in a failure to meet acceptance criteria or cause an adverse effect on a safety system.
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