ML18033B697
| ML18033B697 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/10/1991 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9105150157 | |
| Download: ML18033B697 (13) | |
Text
ACCELERATED DISTRIBUTION DEMONSTPATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
SUBJECT:
Responds to NRC 910412 ltr re violations noted in insp repts
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incident investigation of event conducted
& memo given to contractor involved in incident re recurrence.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL
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TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation Response P
05000259 05000260 05000296 E
NOTES:1 Copy each to: B.Wilson,S.
BLACK 1 Copy each to: S.Black,B.WILSON 1 Copy each to: S.
Black,B.WILSON CESSION NBR:9105150157 DOC.DATE: 91/05/10 NOTARIZED: NO DOCKET g
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
'ECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
TERNAL:
RECIPIENT ID CODE/NAME HEBDON,F ACRS AEOD/DEIIB DEDRO NRR SHANKMAN,S NRR/DOEA/OEAB NRR/DRIS/DIR NRR/PMAS/ILRB12 R ~"--,0.2 COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME ROSS,T.
AEOD AEOD/TPAB NRR MORISSEAU I D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9 D NRR/DST/DIR SE2 NUDOCS-ABSTRACT OGC/HDS3 RGN2 FILE 01 COPIES LTTR ENCL 1
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1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE iVASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO EL!A!INATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
OTAL NUMBER OF COPIES REQUIRED:
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Tennessee Vaiiey Authority, 110t Market Street, Chattanooga. Tennessee 37c02 Mark O. Medford Vice Presirtent. Nuciear Assurance, Licensing anti Fuels MAY 10 1891 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 BROfritHS FERRY NUCLEAR PLANT (BFH)
HRC INSPECTION REPORT 50-259,
- 260, 296/91 REPLY TO NOTICE OF VIOLATION (NOV)
This letter provides TVA's reply to,the NOV transmitted by letter from B. A. wilson to Dan A. Nauman dated April 12, 1991.
In this letter NRC cited TVA with a violation of 10 CFR 50, Appendix B, Criterion V because a Unit 2 mechanical ventilation and air flow dr'awing was not appropriate to the circumstances, in that certain fire isolation dampers were not indicated on the drawing.
TVA agrees that the example noted in the NOV violated regulatory requirements.
Enclosure 1 to this letter is TVA's "Reply to the Notice of Violation" (10 CFR 2.201).
Enclosure 2 is a list of the commitments being made in this reply.
If there are any questions regarding this response please telephone Patrick P. Carier at (205) 729-3570.
Ver:y truly yours, TEHHESSEE VALLEY AUTHORITY Mark 0. Medford Enclosure cc:
See page 2
. 9105150157 pi0510 PDR
- DOCK 05000259 Q
U.S. Nuclear Regulatory Commission hlAY 1 (I 1%1 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 Regu lator y Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Project Chief U.S. Huclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Enclosure 1
Tennessee Valley Authority Browns Ferry Huclear Plant (BFH)
Reply to Notice of Violation (HOV)
Inspection Report 50-259 260 296/91-06 I.
INTRODUCTION In accordance with the Commission's Rules of Practice and Procedure, as described in the HRC.Staff's April 12, 1991 letter transmitting the subject NOV, TVA hereby replies to the NOV in accordance with the CFR 2.201.
requu'ements of 10 II.
SUMMARY
OF POSITION The NOV identified a discrepancy between a drawing and the plant configuration; fire isolation dampers installed in the plant were not
'reflected on the drawing.
TVA agrees that this example violated regulatory requirements.
The discrepancy between the plant configuration and the drawing was previously discovered by TVA during system walkdowns which were conducted as part of the Design Baseline Verification Program.
This discovery led to the issuance of a drawing discrepancy (DD) to add the missing dampers to'ffected drawings.
However,, during implementation of the DD a personnel error caused one of the affected drawings to be revised without the dampers being reflected.
Tn response to this event, TVA corrected the drawing, and conducted a
review to determine if any generic implications existed.
From the results of this review TVA concluded that no generic concerns existed.
Therefore, TVA considers this event an isolated incident not indicative of a breakdown or weakness in the system return to.,service program.
Page 2 of 4 III.
REPLY TO THE HOV A.
The HOV states:
"10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings'equires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, on March 6, 1991, the Unit. 2 Mechanical Ventilation and Air Conditioning Air Flow Diagram, 2-47E2865-4, Revision 6, was not appropriate to the circumstances in that fire isolation dampers for the 2A and 2B 480 Volt Shutdown Board Rooms were not indicated on the drawing.
This drawing is a 'primary drawing used in the control room.
,The system return to service review was completed on February 19, 1991, but this problem was not identified.
This is a Severity Level IV Violation (Supplement I) applicable to unit two."
TVA's Res onse Admission of Violation TVA agrees that the deficiency violates regulatory requirements.
This event was the result of personnel error.
The personnel responsible for resolving an existing DD erroneously concluded in a supplement to the DD that drawing 2-47E2865-4 was not impacted by the DD.
This DD was issued to document the location and specific component identification numbers of dampers on drawings 0-47E865-4 and 2-47E2865-4.
On June 6, 1988, DD 7-88-0513 was issued to document the location and specific component identification numbers of dampers on drawings 0-47E865-4 and 2-47E2865-4.
A proposed resolution to this DD was issued on May 9, 1990; part of this proposed'esolution was to add the four dampers cited in the HOV and a fifth damper to drawing 2-47E2865-4.
Following issuance of the proposed resolution, the drawing revisions were incorporated into TVA's Drawing Improvement
- Program, The purpose of this program is to review outstanding drawing changes to each drawing, including DDs and changes required as a result of plant modifications, so that one revision, rather than several, could be issued.
Once this review is completed, the drawing is scheduled for revision.
The drawings are then revised based on the schedule for system return to service.
Page 3 of 4 During the time that the Drawing Improvement Program review was being conducted, a supplement to the DD was issued which modified the original resolution.
This supplement was issued on November 16, 1990 and stated that drawing,2-47E2865-4 should be deleted from the DD because there was no impact on the drawing.
2.
Corrective Ste s Taken and Results Achieved Following identification of the problem, TVA directed the contractor to conduct an incident investigation of this event.
From. this investigation TVA could not determine the reasons for issuing the incorrect supplement.
The reasons are not documented nor are they known by those most, closely involved with the DD resolution process.
The poI.'sonnel involved in this incident were employed by a TVA contractor.
Since one of these individuals is no longer employed by the contractor, personnel corrective action cannot be taken against this individual.
- However, TVA issued a
memorandum to the contractor which directs the contractor to take appropriate personnel corrective actions against the other individual involved in this incident.
In an effort to prevent.
recurrence of this type event, TVA's memorandum also directs the contractor to ensure that personnel involved in the resolution of DDs 'are made aware of this incident and the subsequent violation, and the impact to TVA that these violations cause.
In addition, TVA directed the contractor to conduct a review to determine if any generic implications existed.
This review addressed the use of DD supplements and examined those DDs where a supplement to the orig,inal resolution was issued.
DD supplements that were issued in the same time frame and involved the same individuals were part of this review.
This review is complete and did not identify any inconsistencies between original resolutions to DDs and supplemental changes to the DDs.
Finally, a supplement to the previous DD was issued on April 14, 1991, to add the five dampers to drawing 2-47E2865-4.
Subsequently, Revision 7 to drawing 2-47E2865-4 was issued on April 30, 1991.
This revision contains the five dampers.
3.
Corrective Ste s Which Will be Taken In an effort to prevent recurrence of this type event, TVA issued a memorandum to the contractor which directs the contractor to ensure that personnel involved in the resolution of DDs are made aware of this incident and the subsequent violation, and the impact to TVA that these violations cause.
This will be completed by July 15, 1991.
Page 4 of 4 4.
Date When Full Co liance Will be Achieved Programmatically, TVA is in full compliance with the requirements of 10 CFR 50, Appendix R, Criterion V, "Instructions, Procedures, and Drawings."
Regarding the specifics of the violation, TVA considers that, it achieved full compliance when the new supplement to the DD was issued.
COHCLVSIOH In conclusion, TVA considers that the example noted in the HOV resulted from personnel error.
That is, individuals involved improperly dispositioned the DD.
Accordingly, TVA considers that this event's not indicative of a programmatic breakdown.
TVA has taken. steps,to correct the specifics of, this example.
V
Enclosure 2
List of Commitments TVA's contractor will make personnel involved in the resolution of drawing discrepancies aware of the incident cited as a violation in HRC Inspection Report 91-06, and the impact to TVA that this violation causes.
This will be completed by July 15, 1991.
I i