ML18036A514

Responds to NRC 920109 Ltr Re Violations Noted in Insp Rept 50-259/91-41,50-260/91-41 & 50-296/91-41 on 911116-911215. Corrective Action:Manager Issued a Verbal Stop Work Order for All Telecommunications Work Associated W/Contract

ML18036A514
Person / Time
Site:	Browns Ferry
Issue date:	02/07/1992
From:	Zeringue O TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9202190062
Download: ML18036A514 (13)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9202190062 DOC.DATE: 92/02/07 NOTARIZED: NO DOCKET FACIL: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 ZERINGUE,O.J. Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 920109 ltr re violations noted in insp rept 50-259/91-41,50-260/91-41 & 50-296/91-41 on 911116-911215.

Corrective action:Manager issued a verbal stop work order for all telecommunicatxons work associated w/contract.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL 1

ID CODE/NAME ROSS,T.

LTTR ENCL 1" 1 HEBDON,F 1 WILLIAMS,J. 1 1 INTERNAL: ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1 AEOD/DSP/TPAB 1 1 DEDRO 1 1 NRR HARBUCKiC ~ 1 1 NRR MORISSEAU,D 1 1 NRR/DLPQ/LHFBPT 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB 1 1 NRR/DREP/PEPB9H 1 1 NRR/DST/DIR SE2 1 1 NRR/PMAS/I LRB12 1 1 NUDOCS-ABSTRACT 1 1 O~R- FTE:, 02 1

1 1

1 OGC/HDS3 RGN2 FILE 01 1

1 1

1 EG EXTERNAL EG&G/BRYCE i J ~ H ~ 1 1 NRC PDR 1 1 NSIC 1 1 t

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

0 Tennessee Valley Authority, Post Ottice Box 2000. Decatur.'Alabama 35609 pEB O7 i<92 O. J. 'Ike'eringue Vice President. Browns Ferry Operations U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of Docket Nos. 50-259 Tennessee Valley, Authority 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) NRC INSPECTION REPORT 50-259, 260, 296/91-41 REPLY TO NOTICE OF VIOLATION (NOV) AND DEVIATION This letter provides TVA's reply to the NOV and deviation transmitted by letter from B. A. Wilson to D. A. Nauman dated January 9, 1992. TVA acknowledges the violation and the deviation.

Enclosure 1 to this letter provides TVA's "Reply to the Notice of Violation and Deviation" in accordance with 10 CFR 2.201 and 10 CFR 2 Appendix C. Enclosure 2 provides a listing of commitments made in this reply.

If you have any questions regarding this response, please contact Raul R. Baron at (205) 729-7570.

Sincerely, r

t jjZ~r(~

0. J. Zeringue Enclosure cc: See page 2 9202190062 920207 P1 i PDR ADOCK 05000259 Q PDR

0 0

0

U.S. Nuclear Regulatory Commission

~EH 07 nm Enclosures cc (Enclosures):

NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens,'labama 35611 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

0 0

ENCLOSURE 1 Tennessee Valley Authority Browns Ferry Nuclear Plant (BFN)

Reply to Notice of Violation (NOV) and Deviation Inspection Report Number "During the Nuclear Regulatory Commission (NRC) inspection conducted on November 16 December 15, 1991, a violation of NRC requirements was identified. The violation involved failure to adequately control design activities. In accordance with the 'General Statement of Policy and Procedure for NRC Enforcement Actions,'0 CFR Part 2, Appendix C (1991), the violation is listed below:

10 CFR 50 Appendix B, Criterion III, Design Control, requires that measures shall be established for the identification and control, of design interfaces and for coordination among participating design organizations. These measures shall include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interfaces.

Site Procedure, SDSP-16.17, Contractor and -Contractors Equipment Controls, required that for documentation associated with Design Change Notices or Engineering Change Notices review and approval shall be per applicable site procedures.

Contrary to the above, activities involving design control were not implemented in accordance with requirements in that during the installation of upgraded communications equipment, subcontractors activities were not adequately- controlled by their design organization or by Nuclear Engineering, the site design organization. Work Plans were not utilized to implement a design change and on October 13, 1991, the subcontractor cut electrical cables servicing two Personnel Radiological Accountability System readers used to account for personnel during a radiological event.

This is a Severity Level IV Violation (Supplement I) applicable to all three units."

0 Enclosure 1 Page 2 of 4 TVA did not have adequate controls in place to ensure the contractor was meeting its contractural requirements. The site coordinator for the telecommunications project did not administer adequate supervision over the contractor, in that he failed to ensure the contractor was complying with the site work control process. The coordinator was not familiar with site procedural control requirements and did not verify work plans were in place prior to the start of work.

Contributing to this was the lack of involvement by site personnel, inadequate direction provided by responsible management, and the failure to use the site procedure (Site Director Standard Practice

[SDSP]-16.17) for controlling contractor activities. The telecommunications project contract and design were developed and managed at the corporate level resulting in only peripheral participation at the site level (i.e., design changes were reviewed and approved in accordance with the site program, but site personnel did not become involved in the project). The site coordinator did not understand his responsibilities due to poor communication by his management.

v t k t v Upon learning that the Personnel Radiological Accountability System cables were cut by telecommunications personnel, the BFN site support manager issued a verbal stop work order for all telecommunications work associated with the contract. The site communications engineer was provided training, which consisted of reviewing procedures that address the handling of contractors and maintenance. A condition adverse to quality report was initiated and Site Quality issued a formal stop work order on the telecommunication project.

Q~ggt v t t v k t v th 3LMCLtiQnM All telecommunications work will be coordinated through the Modifications organization, who will be responsible for ensuring site work practices are followed. Additionally, BFH will baseline contractors authorized to perform work within the protected area to ensure all contractors are assigned to a TVA organization aware of site work control practices. The baselining will be completed by February 24, 1992.,

A new contractor release/work control standard practice, which establishes a technical contract manager (TCM) for TVA contractors, will be completed by March 9, 1992. This standard practice will supercede SDSP 16.17. The TCM will be required to verify proper orientation, training, and interfacing of contractors and their subcontractors with TVA organizations, including Quality Assurance, when required. In addition, the Contractor Work Release (CWR) program requires contractors to impose controls on each of their subcontractors.

Enclosure 1 Page 3 of 4

4. Date When Full Com liance will be Achieved TVA considers that full compliance will be achieved upon completion of the corrective actions for baselining contractors at BFN and the issuance of the new standard practice. These corrective actions will be completed by March 9, 1992.

~BVIATI0 "During an NRC inspection conducted on November 16 December 15, 1991, a deviation from your reply to Notice of Violation 91-26-02 for your actions taken to control contractor activities was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Action", 10 CFR Part 2, Appendix C, 1991, the deviation is listed below:

TVA in reply to Notice of Violation 91-26-02 dated October 9, 1991, stated that action taken to improve the control of inspection requests of contractor walkdown activities would be resumption of these activities using a phased approach.

Contrary to the above, on November 4, 1991, construction contractor walkdown activities were not resumed using a phased approach.

Contractor personnel performed safety related work during a walkdown inspection involving partial removal of a secondary containment boot under work order 91-422447-00. The contractor involved had only been released for non quality activities such as scaffold erection.

Performance of safety related work activities was not scheduled to be released until December 9, 1991.

This deviation is applicable to Unit 3."

1. Reason for the Deviation TVA determined that the work performed outside the scope of the CWR was the result of Stone 6 Webster Engineering Corporation (SWEC) management's failure to clearly communicate the scope of the Contractor/Subcontractor Work Release to SWEC managers, supervisors, and engineers. The removal of the safety-related piping penetration boot by SWEC, to support the walkdown group, was beyond the scope of TVA administrative requirements established by a CWR dated October 21, 1991. The CWR did not release SWEC to perform safety-related work.

In early October, the walkdown group initiated a work request to remove the boot at a penetration in the Unit 3 Reactor Building to allow data verification of pipe supports. On November 4, 1991,

0 Enclosure 1 Page 4 of 4 after receiving the reviews, evaluations, and permits required by procedure, the penetration boot was removed, walkdown data was obtained, and the boot was reinstalled and then inspected by TVA Quality Control. The work was implemented properly (i.e.,

authorized by Plant Operations and conducted in accordance with procedure).

On November 14, 1991, a TVA QA representative became aware of the work performed on safety-related equipment during a weekly status meeting and questioned whether the work was within the scope of the CWR. SWEC reviewed the work order and agreed that it was outside the scope of the CWR and issued a stop work memorandum.

2. Corrective Ste s Taken and Results Achieved All work orders were withdrawn from construction until they could be reviewed for scope definition. SWEC supervisors and engineers were retrained in the CWR program. As corrective action, TVA issued a memorandum on November 20, 1991, outlining enhancements to the work release process, which included requirements to ensure that the scope of work is directly communicated to line supervision. TVA

.Restart organization and contractor managers, who manage contractor field activities, were briefed on this incident and the potential implications by December 6, 1991. Interim written guidance for controlling contractor field work activities for Unit 3 restart was issued on December 9, 1991, and will be used until a site instruction is implemented. No further corrective action is considered necessary.

3. Corrective Ste s that have been or will be Taken to Avoid Further, Deviations A site instruction will be issued by March 9, 1992 to ensure that CWRs are properly controlled (reference TVA's response to NOV 91-41-02, which precedes this deviation response).

4. Date When Full Com liance will be Achieved Full compliance will be achieved by March 9, 1992.

ENCLOSURE 2' Tennessee Valley Authority Browns Ferry Nuclear Plant /,.8)

Reply to Notice of Violation (NOV) and Deviation Inspection Report Number 6

1. BPÃ will baseline contractors authorized to perform work within the protected area and ensure they are assigned to a TVA organization aware of site work control practices. This will be completed by February 24, 1992.

2. TVA is writing a new contractor release/work control standard practice to establish a technical contract manager overview of contractors and require contractors to impose controls on each of their subcontractors. This standard will be completed by Narch 9, 1992.