ML18033B597

Responds to NRC 901108 Ltr Re Violations Noted in Insp Rept 50-259/90-29,50-260/90-29 & 50-296/90-29.Corective Actions: Mod Foreman Reprimanded & Retrained & Event Reviewed W/Sys Evaluators & Tagging & Support Coordinators

ML18033B597
Person / Time
Site:	Browns Ferry
Issue date:	12/28/1990
From:	Medford M TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9101090152
Download: ML18033B597 (14)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ESSION NBR:9101090152 DOC.DATE: 90/12/28 NOTARIZED: NO DOCKET 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 901108 ltr re violations noted in Insp Rept D 50-259/90-29,50-260/90-29 & 50-296/90-29.Corective actions:

mod forMan reprimanded & retrained & event reviewed w/sys evaluators & tagging & support L

coordinators.'ISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation Response A

NOTES:1 Copy each to: B.Wilson,S. BLACK 05000259 1 Copy each to: S.Black,B.WILSON 05000260 1 Copy each to: S. Black,B.WILSON 05000296 D

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR. ENCL HEBDON,F 1 1 ROSS,T. 1 1 I TERNAL: ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1' AEOD/TPAB 1 1 DEDRO 1 NRR MORISSEAU,D 1 '1 NRR SHANKMAN,S 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB 1 1 NRR/DREP/PEPB9D 1 1 NRR/DRIS/DIR 1 1 NRR/DST/DIR 8E2 1 1 NRR/PMAS/I LRB12 1 1 NUDOCS-ABSTRACT 1 1 OE 1 1. OGC/HDS3 1 1 G FTrh 02 1 1 RGN2 FILE 01 1 1 EXTERNAL EG & G/BRYCE i J ~ H ~ 1 1 NRC PDR 1 1 NSIC 1 1 NOTES: 5 5 D D

D NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! COiNTACT THE DOCUMENT CONTROL DESK, ROOli'I PI-37 (EYT. 20079) TO ELliillNATE YOUR NAME FROID DISTRIBUTION I.ISTS I OR DOCU)ilEiNTS YOU DON'T NEED!

TAL NUMBER OF COPIES REQUIRED: LTTR 29 ENCL 29

TENNESSEE VALLEY AUTHORITY 5N 157B Lookout Place GEc 38 1990 U.S. Nuclear Regulatory Commission ATTN:'ocument Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of Docket Nos. 50-259 Tennessee Valley Authority 50-260 50-296 BROWS FERRY NUCLEAR PLANT (BFN) NRC INSPECTION REPORT 50-259, 260, 296/90-29 RESPONSE TO NOTICE OF VIOLATION This letter provides TVA's response to the Notice of Violation transmitted by letter from B. A. Wilson to 0. D. Kingsley, Jr. dated November 8, 1990. NRC cited TVA with a violation with two examples for failure to follow t

procedures. The first example involved personnel working within an equipment clearance boundary without proper authorization on a hold order. The -second, example involved an improperly completed impact evaluation of work activities which resulted an an unplanned engineered safety features actuate.on.

0 Enclosure 1 provides TVA's response to this violation. Each example is addressed separately along with the corrective actions taken.

On December 17, 1990, NRC issued Inspection Report 90-33 which cited two new.

self-identified examples of the problem identified in this violation. TVA will address both of these examples in a supplement to this letter. The supplement will be submitted by January 31, 1991.

II staff, J

As agreed with members of the NRC Region the due date for this was extended, to December 31, 19+. 'esponse Enclosure 2 is a listing of the commitment made in this response.

If you have any questions regarding this response, please telephone Patrick P. Carier at (205) 729-3570.

Very truly yours, TENNESSEE VALLEY AUTHORITY gg gi 4<

M. 0. Medford, Vice President Nuclear Assurance, Licensing and Fuels Enclosure cc: See page 2 9101090152 901228 PDF'DGCI." 050002'=

f,i PDR 9

An Equal Opportunity Employer g Eo/

I/

l, l

U.S. Nuclear Regulatory Commission cc (Enclosure):

Ms. S. C. Black, Deputy Director Project Directorate 11-4 U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike, Rockville, Maryland 20852 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000 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

ENCLOSURE 1 RESPONSE BROWNS FERRY NUCLEAR PLANT NRC 'INSPECTION REPORT 50 259'60~ 296/90 29 LETTER FROM B. A. WILSON TO 0. D. KINGSLEY, JR.

DATED NOVEMBER 8, 1990 During the NRC inspection conducted between September 16 and October 15, 1990 a violation of NRC requirements for failing to follow procedures was identified. The first example of this violation involved personnel working inside an equipment clearance without proper authorization on a hold order.

The second example involved an improperly completed impact evaluation of work activities which resulted in an unplanned engineered safety features (ESF) actuation.

Technical Specifications, Section 6.8.1, Procedures, requires that written procedures shall be established, implemented and maintained covering those recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A of Regulatory Guide 1.33 includes administrative procedures and procedures for controlling repair activities of safety-related equipment.

Site Directors Standard Practice (SDSP)-7.9, Integrated Schedule and Work Control, Section 6.4.1, requires that an impact evaluation be performed on all activities that have potential for affecting equipment operations which may affect the safe and reliable operation of the unit except as specifically exempted. Attachment C to SDSP-7.9 is used to document that evaluation.

Section 7.0 specifies the Tagging and Support Coordinator's duties in reviewing, correcting, and issuing hold order boundaries.

SDSP-14.9, Equipment Clearance Procedure, Section 6.1 provides both general and special requirements for removing equipment from service to allow work to safely proceed.

Contrary to the above, these requirements were not met for the following two examples:

l. On August 25, 1990 the requirements were not met in that Workplan 0252-90 was determined to be in progress without appropriate supervision having signed onto an existing hold order.

2. On September 16, 1990 the requirements were not met in that an inadequate impact evaluation resulted in licensee personnel cutting energized electrical leads that were part of the D Diesel Generator initiation logic circuits. This activity resulted in an unplanned engineered safety feature actuation.

This is a Severity Level IV Violation (Supplement A

I) applicable to all three units ~

t x TVA admits the violation.

This violation occurred due to personnel error. The lead Modifications foreman responsible for signing on to the hold order failed to sign on to the hold order prior to the work being performed.

On August 16, 1990 while preparing to implement a workplan, modifications personnel contacted the lead modifications foreman and requested that he sign the workplan on to an existing hold order. After receiving the" request, the lead foreman noted in the Modifications organization's log book, which lists hold orders and denotes specific workplans covered by each hold order, that he had signed on to a hold order. Modifications personnel responsible for performing the work reviewed the log book, confirmed that'the lead foreman had signed the workplan on the existing hold order, and proceeded to implement the workplan. However, although the lead foreman had noted in the log book that he had signed on to a hold order he never contacted appropriate plant personnel to have the workplan signed on to the hold order. Signing on to hold orders prior to implementing workplans is required by Site Director Standard Practice (SDSP) 14.9, Equipment Clearance Procedure, if equipment must be removed from service to perform work.

t v t v . n k v The Modifications foreman associated with this event received a reprimand from his supervisor. This foreman was also retrained in the requirements of SDSP 14.9. This training was conducted by a Shift Operations Supervisor and specifically emphasized the correct preparation of tagout requests, the purpose of equipment clearances (to protect personnel and equipment), responsibilities of the Operations organization for establishing clearance boundaries, and responsibilities of the Modifications organization for walking down and verifying established boundaries before beginning work. Prior to completing this training the foreman was restricted from signing on to hold orders.

t v th r Rhd ~t'a To prevent further recurrence of this type of event, Modifications management, general foremen and foremen were retrained in the requirements of SDSP 14.9. The specifics of this training are discussed above. This training has been completed.

5. v TVA considers that it has achieved full compliance with the specifics of 1.

TVA m'h this example of the admits the violation.

violation.

2.

This violation occurred due to personnel error on the part of the individuals responsible for preparing and reviewing the impact evaluation sheet.

SDSP 7.9, Integrated Schedule and Work Control, requires that scheduled work activities be evaluated for impact on plant equipment. This evaluation is documented on, Attachment C, Plant Operation Impact Evaluation Sheet (POIES). Individuals responsible for preparation and review of the POIES are responsible for identifying significant component and system responses such as ESF actuations, in addition to determining whether work will be within a hold order boundary. Specifically, the Work Control System Evaluator (or system evaluator) is responsible for developing a ". . . suggested Hold Order that encompasses all the work that can be logically done under a given set of boundaries." The Tagging and Support Coordinator is responsible for ". . . review[ing] and correct[ing] the suggested Hold Order boundaries."

In this event, the system evaluator was assessing the impact of two work orders directing replacement of Raychem splices on the leads to two reactor vessel level transmitters. These work orders were among approximately 15 other work orders directing replacement of Raychem splices. Because several of the other work orders involved reactor protection system (RPS) components, the system evaluator incorrectly assumed that the work would affect RPS components instead of emergency core cooling system components. Based on this, he concluded that the work could be performed under an existing hold order for RPS components. The system evaluator then provided this assessment to the Tagging and Support Coordinator.

During his review of the assessment, the Tagging and Support Coordinator questioned personnel performing the work, and their supervisor, regarding the appropriateness of the suggested hold order boundary. Based on this information and the assessment provided by the system evaluator, the Tagging and Support Coordinator incorrectly determined that the work could be performed under the existing hold order.

(~

o

3. t'v t t '

The Plant Operations Manager reviewed this event with the Work Control Manager and the Operations Superintendent. These managers have in turn taken appropriate corrective actions with the system evaluator and the Tagging and Support Coordinator associated with this event.

4, t' In order to prevent further recurrence of this type of event, TVA reviewed this event with the system evaluators and the Tagging and Support Coordinators to stress the importance of properly and thoroughly completing the impact. evaluation sheet for each work activity to be performed. In, addition, the importance of Operations personnel performing a thorough review prior to work approval was stressed.

5. t h n A v TVA considers that it has achieved full compliance with the specifics of this example of the violation.

ENCLOSURE 2 COMMITMENT RESPONSE BROWNS FERRY NUCLEAR PLANT NRC INSPECTION REPORT 50-259, 260, 296/90-29 LETTER FROM B. A. WILSON TO 0. D. KINGSLEY, JR.

DATED NOVEMBER 8, 1990 On December 17, 1990, NRC issued Inspection Report 90-33 which cited two new self-identified examples of the problem identified in this violation. TVA will address both of these examples in a supplement to this letter. The supplement will be submitted by January 31, 1991.