ML18036A367

Responds to NRC Re Violations Noted in Insp Repts 50-259/91-23,50-260/91-23 & 50-296/91-23 & Proposed Imposition of Civil Penalty in Amount of $75,000.Employee Training Sessions Conducted from 910607-12

ML18036A367
Person / Time
Site:	Browns Ferry
Issue date:	09/06/1991
From:	Medford M TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
EA-91-083, EA-91-83, NUDOCS 9109110220
Download: ML18036A367 (13)

Text

ACCELERATED DISTBZBUTION DEMONSTRATION SYSTEM h

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ESSION NBR:9109110220 DOC.DATE: 91/09/06 NOTARIZED: NO ACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee AUTH.NAME AUTHOR AFFILIATION MEDFORD,M.O.

Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Ofc of Enforcement (Post 870413)

DOCKET I 05000259 05000260 05000296 R

SUBJECT:

Responds to NRC 910807 ltr re violations noted in Insp Repts 50-259/91-23,50-260/91-23

& 50-296/91-23

& proposed imposition of civil penalty in amount of $75,000.Employee training sessions conducted from 910607-12.

DISTRIBUTION CODE: IE14D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: Enforcement Action Non-2.790-Licensee

Response

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1 RECIPIENT ID CODE/NAME HEBDON,F WILLIAMS,J.

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NOTE TO ALL"RIDS" RECIPIENTS:

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D PLEASE HELP US TO REDUCE iVASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOiil PI-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUKIENTS YOU DON'T NEED!

TAL NUMBER OF COPIES REQUIRED:

LTTR 17 ENCL 17

Tennessee Valley Authority, t101 Market Street. Chattanooga. Tennessee 37402 Mark O. Medford Vice President. hluclear Assurance. Licensing and Fuels SEP 06 $91 Director, Office of Enforceme'nt 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 BROWNS FERRY NUCLEAR PLANT (BFN)

NRC INSPECTION REPORT 50-259,

260, 296/91-23' REPLY TO NOTICE OF VIOLATION (NOV) AND PROPOSED IMPOSITION OF CIVIL PENALTY (EA 91-083)

This letter provides TVA's reply to S.

D. Ebneter's letter to D. A. Nauman dated August 7, 1991 which transmitted the subject NOV involving the breach of primary containment event.

TVA, was cited with three violations:

Violation A for failing t'o maintain primary containment integrity when required by the Technical Specifications, Violation B for failing to follow procedures when a Maintenance craftsman defeated the drywell interlock without authorization of the Shift Operations Supervisor, and Violation C for failing to have adequate procedures to maintain containment integrity.

TVA fully recognizes the serious nature of the June 5,

1991 event, as evidenced by the prompt and comprehensive corrective actions taken, including a thorough review of plant procedures and implementation of procedural enhancements.

In order, to reinforce the need for a safety conscious operational philosophy, plant management developed a training package and conducted employee training sessions with essentially all plant personnel from June 7 through June 12, 1991.

These sessions provided final event description, plant personnel responsibilities, Shift Operations Supervisor responsibility/authority, and attitude and response to issues.

These sessions complemented TVA's previous efforts, during the latter stages of the Unit 2 recovery effort, to stress its expectations regarding the proper operating philosophy.

r rnn 91091102~0 910906 PDR ADQCfr, 05000259 0

PDR

U.S. Nuclear Regulatory Commission SEP 06 1991 Pursuant to 10 CFR 2.201 and as described in the enclosed "Reply to the Notice of Violation," TVA= admits these violations.

Payment of the proposed civil penalty in the amount of $75,000 is being made by electronic fund transfer.

If you have any questions regarding this response, please telephone O. J. Zeringue at (205) 729-3675, or myself at (615) 751-4776.

Very truly yours, TENNESSEE VALLEY AUTHORITY Pgm 8 M. 0. Medford, Vice President S ory to before me this day of S p

mber, 1991 Notary Public My Commission Expires:

Enclosure cc (Enclosure):

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

ENCZOSURE 1 Tennessee Valley Authority Browns Perry Nuclear Plant (BFN)

Reply to Notice of Violation (NOV) and Proposed Imposition of Civil Penalty Inspection Report Number

-2 26 2 /

-2 vIIILLATI8 "During an NRC inspection conducted on June 5 June 12, 1991, violations of NRC requirements were identified.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1991), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant,to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C.

2282, and 10 CFR 2.205.

The particular violations and associated civil penalty are set forth below:

Technical Specification 3.7.A.2.a requires that primary containment integrity shall be maintained at all times when the reactor is critical or when the reactor water temperature is above 212 degrees F.

and fuel is in.

the reactor vessel.

Contrary to the above, on June 5, 1991, while the Unit 2 reactor was critical at 150 psig and 365 degrees F., primary containment integrity was not maintained in that both drywell personnel access doors were open at the same time from 2:45 a.m. until 6:45 a.m.

B.

Technical Specification 6.8.1.1 requires that written procedures shall be established, implemented and maintained covering the applicable procedures in Appendix A for Regulatory Guide 1.33 Revision 2, February 1978.

Appendix A includes procedures for access to containment and maintenance of containment integrity.

Mechanical Maintenance Instruction (MMI) 129, Drywell Personnel Airlock

Doors, developed to implement the requirements of Appendix A to Regulatory Guide 1.33, identifies employees that are qualified and authorized to operate and disable drywell personnel access door interlocks and to define the steps necessary to open and close the personnel airlock doors upon issuance of a maintenance request.

Section 8 requires, in part, that

[except in an emergency]

when the Shift Operations Supervisor has informed the foreman that primary containment is not required, a work request be initiated to defeat the access door interlocks.

Page 2 of 7 Contrary to the above, on June 5,

1991, the drywell personnel airlock door interlock was defeated by plant maintenance personnel without authorization from the Shift Operations Supervisor that primary containment was not required and no emergency condition was present.

C.

Technical Specification 6.8.1.1 requires that written procedures shall be established, implemented and maintained covering the applicable procedures in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Appendix A includes procedures for access to containment and maintenance of containment integrity.

Site Director Standard Practice (SDSP) - 14.15, Entry and Work In The Primary Containment, Revision 3, prescribes the requirements for entry and work in the primary containment under conditions when the control rods are in full-in position and fuel is in the reactor pressure vessel.

Contrary to the above, on tune 5, 1991, the, licensee failed to establish adequate procedures to maintain containment integrity during the collection of piping thermal expansion data with the control rods not in full-in position and'uel in the reactor pressure vessel and the reactor critical.

Specifically, SDSP-14.15, Revision 3, contained no requirement to assure that at least one airlock door remained closed at all times.

Violations A, B and C have been categorized in the aggregate as a Severity Level III problem (Supplement 1)."

TVA'S REPLX 1.

Admi i n of Vi 1 i ns TVA admits these violations.

2.

Rea n for Vi 1 ti ns

~ The primary cause of these violations was an unauthorized personnel action.

The Mechanical Maintenance craftsman performed thi's unauthorized work by disarming the interlock on the drywell airlock.

The craftsman had received no direction from his supervisor or the Shift Operations Supervisor (SOS) to perform this work.

In addition, the craftsman did not have written authorization allowing him to perform this work.

A contributing cause of this event was the lack of action taken by those in the direct area during the event.

Another contributing factor was the failure of existing procedures to adequately control containment entry.

During the Unit 2 power ascension test program, drywell entries were required to verify proper thermal expansion of primary system piping.

This testing was being performed in accordance with Test Instruction (TI)

190, S

s em Thermal Ex nsion, with reactor coolant system pressure at approximately 150 psig.

Mechanical Maintenance craftsmen were designated to operate the drywell airlock doors.

These individuals were the assigned and qualified personnel to perform this task.

Page 3 of 7 At approximately 0040 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> on June 5,

1991 Mechanical Maintenance was dispatched to assist in operating the airlock doors to support the thermal expansion testing.

After supporting three entries into the drywell to determine the radiological conditions, a brief discussion took place between a Maintenance craftsman assigned to operate the drywell doors and a Radiological Controls technician.

Based on this discussion the

,craftsman understood it was acceptable to defe'at the airlock interlock and open both inner and outer doors, providing an unobstructed pathway into the drywell.

After defeating the airlock interlock, the craftsman reported his action to his foreman and general foreman.

Although they were aware that such action was inappropriate, these individuals did not question this action and failed to notify the SOS.

At approximately 0600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> on June 5,

1991 the status of the airlock was questioned and the condition reported to the SOS.

(The method util'ized to defeat the airlock interlock had caused the door position indication in the control room to be erroneous.)

Following this notification the SOS took appropriate actions and reestablished primary containment integrity at approximately 0645 hours0.00747 days <br />0.179 hours <br />0.00107 weeks <br />2.454225e-4 months <br />.

E 3.

rr i e S

T k n n

R ult Achi Upon notification immediate corrective action was taken by the SOS to re-establish primary containment integrity.

As stated in the licensee event report (LER) concerning this event (LER 260/91013, Revision 1) corrective actions have been implemented in'everal areas to address the specifics of this event.

The areas and their respective corrective action(s) are provided below.

a.

Vr mm ic i n - Without proper authorization, the Maintenance craftsman modified the assigned scope of work.

The foreman and general foreman failed to react to the unauthorized personnel action after becoming aware of it.

rr i

A i n Plant management developed an operating plant philosophy training package and conducted employee training sessions with essentially all plant personnel from June 7 through June 12,,

1991.

These sessions provided final event description, plant personnel responsibilities, SOS responsibility/authority, and attitude and response to issues.

In addition, the training sessions addressed specific examples of previous events involving poor foreign material control, failures to perform adequate self-verification and problems associated with configuration control and equipment manipulation.

b.

W rk Pr i

The craftsman defeated the interlocks without proper authorization and work documentation as required by plant procedures.

rr ive A i ns In addition to the training described in item a.

above, TVA has trained Maintenance craft and craft supervision on the requirements for the performance and documentation of assigned work.

TVA also revised its training programs for Maintenance craftsmen to ensure that these requirements are stressed during the craft initial training and are reinforced during the craft annual retraining.

The revised training program became effective August 15, 1991.

Page 4 of 7 c ~

A f Pr c d r Existing procedures were not adequate to control containment entry.

In addition, the risks and consequences associated with changing the method of defeating interlocks were not adequately reviewed or assessed for applicability during a 1987 revision of the procedure for defeating the interlocks.

r A

i'

- Unit 2 Operating Instruction 2-0I-64, prim~

n m

r in In

, has been revised to require that at least one of the two airlock doors be closed at all times when primary containment is required.

The higher tier document, Site Director Standard Practice 14.15, En r n

W rk in h

Prim r while primary containment is required be performed in accordance with 2-0I-64.

Furthermore, TVA enhanced Operating instructions to ensure Operations personnel are responsible for operation of the drywell doors.

Maintenance instructions for defeating drywell interlocks have also been improved to ensure correct drywell airlock 'door status is indicated in the control room with the interlocks defeated, and to remove responsibility and authority of operation of the drywell airlock from the Maintenance craft.

In addition, TVA has reviewed plant procedures (over 2000) to ensure that all primary and secondary containment interlock mechanisms are properly controlled.

Based on the results of this review plant procedures were enhanced as, necessary to improve control over interlocks.

d.-

Man ri 1

M Prior to this event, plant management had met with plant personnel on several occasions to emphasize the importance of recognizing that BFN is becoming an operating plant, including the increased technical specification and operating requirements which would be in effect.

Discussions included emphasis on correct job performance (e.g.,

ensure adequate time is taken; ensure each activity is clearly understood, if not, stop; if equipment failures occur, ensure proper actions are taken to determine root cause; self-checking).

Several in-house assessments, including independent reviews (e.g.,

Operational Readiness Review, Senior Management Assessment) were conducted to assess the readiness of personnel to resume operations.

While significant improvements were noted, management recognized that continuous, sustained emphasis and actual

.operating performance, would be necessary to obtain desired levels of excellence.

Frequent management assessments of operational performance were included in the Power Ascension Program.

i A

Training as discussed in item a.

above was given to plant personnel.

Site Quality Assurance (QA) performed surveys to determine the effectiveness of this training.

Based on these

surveys, additional training was provided in the Maintenance area.

In

addition, the site Training department has enhanced the general employee training (GET) program to emphasize the importance of the plant's safety barriers and the responsibility to maintain their effectiveness.

GET training also stresses the responsibility of all employees to follow procedures.

This enhanced training became effective July 1, 1991.

Page 5 of 7 e.

n h riz r In r ri P

nn 1

A i n The Mechanical Maintenance craftsman performed unauthorized work in violation of plant procedures, and two foremen failed to take appropriate action upon learning that the interlock was disarmed.

rr i n

- These personnel received disciplinary action in accordance with TVA policy.

In addition, the individuals that observed the doors 'were open but did not question that condition were counseled.

In addition to the above corrective actions, TVA management performed an independent review of the event to identify areas in which improvements may be prudent to further enhance maintenance-related activities and to reinforce requisite operational attitudes.

This review resulted in the development of the comprehensive set of improvements listed below.

as Pr c

re Enh n men's - The plant instruction governing work request n

m n m, contained adequate controls to ensure Operations notifications and authorization prior to commencing work.

The procedure

has, however, been enhanced to improve the process for notifying Operations of the status of in-progress work.

Specifically, it has been enhanced to ensure that if during performance of a work order (WO) any significant delays (over four hours) and scope changes occur,.the SOS and unit operator are notified.

The work planner's-guide has also been improved to reflect this enhancement.

In addition, for work that affects certain critical systems, a "red sheet" must be filled out and inserted in the front of the work package as a flag to alert craftsmen of potential adverse impacts on plant operations.

b.

hif T rn r

- To ensure proper attendance and information exchange during SOS turnover meetings, General Operating Instruction 300-1, Attachment A,

Turn r Che kle s

was enhanced to clearly identify the individuals scheduled to attend the shift turnover.

The turnover checklist was also enhanced to include a listing of power ascension tests that would be carried over into the oncoming shift.

In

addition, the checklist now requires the listing of prejob briefings to ensure the oncoming shift receives a briefing on the work activities/test activities in progrbss.

c ~

R iew The site Qh organisation performed a review of open Wos.

No WOs were identified where Operations notifications were not being made.

The review revealed that 12 of the WOs required minor changes or improvements in the way Operations notifications were being

provided, and 14 WOs were unnecessary and needed to be closed or canceled.

TVA determined that no problems would have resulted from execution of these WOs.

The remaining WOs were'found to have adequate scope and work controls.

QA also independently reviewed over 700 of

~Pr

< e~u~rs.

d.

Pr t Briefin

- To enhance the conduct of job briefings, guidelines were issued to test directors to reemphasize compliance with procedural requirements for conducting briefings for power ascension testing.

These guidelines required that pretest briefings be held on the shift during which the test is performed; that

Page 6 of 7 personnel directly or indirectly involved in performance of. the test be present at. the briefings; and that the test director conduct two pretest briefings:

one prior to the test crew assuming shift duties (a general test overview, usually at the Operations shift turnover meeting) and a second prior to commencing the test (a detailed briefing).

Briefings ensure that test crews understand the test criteria, expected plant responses, and required actions.

e.

T sk 1'f' Tr inin - To ensure that required job performance criteria have been addressed, TVA reviewed the task qualification process and found it to be satisfactory.

In addition, line management and QA are monitoring the implementation of this program on an ongoing basis to evaluate the adequacy and effectiveness of the program.

i i i n T

- To ensure that required job performance criteria for Maintenance craftsmen have been addressed, TVA committed, in its June 13, 1991 letter to NRC, to evaluate the applicability of a Peach Bottom type screening and evaluation program for craft personnel.

TVA also committed to evaluate the possibility of using craft screening services provided by the Edison Electric Institute.

To this end TVA administered a skills assessment test to determine the

'abilities of Maintenance craftsmen.

As a result, TVA concluded that the craftsmen possessed the necessary skills to adequately perform their assigned

tasks, and determined that development of a screening and evaluation program for craft personnel is not necessary.

g.

w r As en i n T R i w To ensure that support activities are completely. specified and documented, TVA reviewed the power ascension tests.

Nineteen tests were reviewed; seven of which were improved.

h.

hif T

A r

TA r in'n

- TVA reviewed the current STA training program, which includes senior reactor operator qualification, and found it adequately covers primary containment requirements.

Interviews with individual STAs found them knowledgeable of these requirements.

r n

lifi i n Tr in'n

- TVA has developed a continuing supervisory training program for foremen and general foremen.

This program consists of 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of initial training and 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per year of continuing training.

Topics discussed during the initial training include policies and procedures, performance management, fitness for duty for supervisors, and situational leadership and team building.

During the retraining, technical topics such as procedure preparation, use and revision; plant modifications; industrial safety and radiological protection are addressed.

In addition, the annual retraining addresses administrative areas such as quality assurance and quality control, budgeting, conduct of operations, and plant security.

Page 7 of 7 plant areas obtain the applicable access

level, TVA reviewed access levels of site personnel and changed the level of 108 individuals.

k.

w o r'

A i i i To ensure proper control by Operations, TVA reviewed other critical activities, such as those related to fire protection, radiation monitors, and high radiation doors.

No deficiencies were identified.

n r

n inm n In rl

- To preclude a similar event from occurring on BFN's secondary containment airlocks, TVA checked secondary containment interlocks and verified proper functionality.

in n n M n m n r

r

- To ensure that BFN has an optimum Maintenance management organization, TVA evaluated the two-level Maintenance supervisory structure.

As a result of this review, TVA has changed the management structure.

In the new structure a general foreman (the first level of Maintenance management) is assigned to each Maintenance crew and is the first line supervisor.

TVA is in the process of implementing this new organization.

4.

rr iv Whi h Will B T k n In TVA's June 13, 1991 letter to NRC TVA committed to develop a screening and evaluation program to assess the job performance of Maintenance foremen.

The program includes screening and evaluation of both current foremen and future 'selection candidates to ensure they possess adequate skills to perform their supervisory roles.

A similar program has been successfully implemented at the Peach Bottom plant.

TVA is currently entering the implementation phase of this program.

This phase focuses on the assessment and development of the foremen and is structured as a pilot project using an assessment center process.

The assessment center is a formal system of management and supervisory exercises used to evaluate and develop the successful management characteristics which are important for Maintenance foremen.

Twelve foremen are scheduled to participate in the pilot project.

5.

D e

Wh n Full m li nc Will Be A hiev TVA considers that full compliance has been achieved.

TVA considers that the ongoing actions discussed above are programmatic enhancements and are not necessary to achieve compliance with regulatory requirements.

I

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