ML18036A655
| ML18036A655 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/09/1992 |
| From: | Zeringue O TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-REGGD-01.033, RTR-REGGD-1.033 NUDOCS 9204140336 | |
| Download: ML18036A655 (12) | |
Text
ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
SSION NBR: 9204140336 DOC. DATE: 92/04/09 NOTARIZED:
NO FACIL: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 ZERINGUE,O.J.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Provides response to NRC 920310 ltr re violations noted in Insp Repts 50-259/92-03,50-260/92-03
& 50-296/92-03.
Corrective actions:specific emphasis placed -on use of non-standard terminology.
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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES'OCKET 05000259 05000260 05000296 D
RECIPIENT ID CODE/NAME HEBDON,F WILLIAMS,J.
INTERNAL ACRS AEOD/DEIIB t
DEDRO NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/DST/DIR 8E2 NUDOCS-ABSTRACT OGC/HDS3 RGN2 FILE 01 EXTERNAL: EGGG/BRYCE,J.H.
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1 RECIPIENT ID CODE/NAME ROSS,T.
AEOD AEOD/DSP/TPAB NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/PMAS/ILRB12 OE DIR REG. SILE-~ =0!2 ARC PDR COPIES LTTR ENCL 1
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1 NOTE TO ALL"RIDS" RECIPIENTS:
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PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOiVI P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISI'RIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
AL NUMBER OF COPIES REQUIRED:
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Tennessee Valley Authority. Post Olfice Box 2000, Decatur, Alabama 35609 O. J. 'Ike'eringue Vice President. Browns Ferry Operations g% Po 1992 U.S. Nuclear'egulatory 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 t
BROWNS FERRY NUCLEAR PLANT (BFN) NRC INSPECTION REPORT 50-259,
- 260, 296/92-03 REPLY TO NOTICE OF VIOLATION (NOV)
This letter provides TVA's reply to the NOV transmitted by letter from B. A. Wilson to M. 0. Medford dated March 10, 1992.
In this letter, NRC cited TVA with a violation involving two examples of failure to follow procedures.
Enclosure 1 to this letter is TVA's "Reply to the Notice of Violation" (10 CFR 2 201).
Enclosure 2 to this letter provides a list of commitments made by TVA in response to the NOV.
If you have any questions regarding this response, please telephone Raul R. Baron at (205) 729-7570.
Sincerely, 0
. Zeringue Enclosure cc:
See page 2
//(ti l
0
U.S, Nuclear Regulatory Commission APR 09 i992 Enclosure cc (Enclosure):
NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637
- Athens, Alabama 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
ENCLOSURE l Tennessee Valley Authority Browns Perry Nuclear Plant (BPN)
Reply to Notice of Violation (NOV)
Inspection Report Number 2
"During the Nuclear Regulatory Commission (NRC) inspection conducted on January 17 February 14,
- 1992, a violation of NRC requirements was identified.
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:
Technical Specification Section 6.8.1, Procedures, requires that written procedures shall be established, implemented and maintained covering the surveillance and test activities of safety-related equipment and the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Included in Appendix A are general operating procedures for emergency diesel generators and refueling equipment operation.
Contrary to the above, these requirements were not met for the following two examples:
1.
Site Standard Practice, SSP-12.3, Equipment, Clearance Procedure, establishes the requirements for the safe removal from service and tagging of plant equipment to allow maintenance, modification or testing of plant equipment.
Surveillance Instruction, 1/2-SI-4.9.A.l.d(A), Diesel Generator Annual Inspection, requires that as a prerequisite to performing the testing that the diesel start circuit breakers be covered under a hold order.
Step 7.7.17.1.6 of 1/2-SI-4.9.A.l.d(A) directs that those breakers be closed which requires that the hold order be released.
No steps in this instruction prior to this step provide for release of the hold order or repositioning of the start circuit breakers.
On December 18,
- 1991, the requirements were not met in that during performance of 1/2-SI-4.9.A.l.d(A), the start circuit breakers had already been closed prior to performance of step 7.7.14.1 resulting in an unplanned automatic start of Diesel Generator 1A.
2.
Plant procedure 1/2-POI-78-1, Non-Fuel Transfer Evolutions Using Unit 1 and 2 Transfer Canal, provides precautions, limitations, pre-requisites, and procedural steps for transfer of non-fuel components through the Unit 1/2 transfer canal between the spent fuel pools'his procedure requires signatures by the refueling senior
0
Enclosure 1
Page 2 of 5 reactor operator, shift operations supervisor, and contains steps for securing the transfer canal gates.
On January 31,
- 1992, the transfer
- canal gates were found leaking because the gates were not.properly installed.
Procedure 1/2-POI-78-1, was not used during transfer of cleanup filters between Unit 1 and 2 spent fuel pooled'his work was performed under work order 92-4748-00 which did not reference the procedure.
This is a Severity Level IV Violation (Supplement I)."
&o The cause of this event was inadequate communication which resulted in an inappropriate personnel action.
Specifically, during the performance of this surveillance instruction (SI), an electrical foreman requested, from the Operations organization, the modification of the clearance that had been established to perform this SI.
The clearance modification was required to perform diesel generator A
alarm checks.
The foreman, in accordance with Site Standard Practice (SSP) 12.31
, requested that Operations place the components originally listed on the clearance in the "normal" position.
He also provided a specific list of components which would remain on the clearance and requested the others be removed.
The diesel generator start circuit breakers were inappropriately removed from the clearance at this time.
In this event, TVA has determined that the term "normal" had different meanings for the individuals involved.
To the craft foreman, normal meant in relation to the SI.
That is, normal would be in the open position.
To Operations personnel, normal meant the position of the breakers during normal plant operation.
Accordingly, Operations personnel placed the start circuit breakers in the closed position.
During the-next shift, jumpers were placed to allow performance of alarm checks.
These actions resulted in the inadvertent start of a diesel generator.
Since the diesel generator annual surveillance is performed over multiple shifts, actions started on one shift must be completed on the following shift.
This requires the associated clearances to be signed over to the general foreman of the oncoming shift.
In this event, the general foreman for the oncoming shift failed to recognize, during the review of the clearance boundaries, that the start circuit breakers were closed.
TVA's investigation into this event has shown that the SI used to perform the diesel generator annual inspection was correct and if properly implemented this event would not have occurred.
In fact, this procedure has been performed successfully during previous diesel generator inspections.
= Nevertheless, TVA has enhanced this procedure to provide additional guidance on equipment alignment.
This guidance will ensure that an event of this type does not reoccur.
0
Enclosure 1
Page 3 of 5 In the NRC inspection report, the Staff expresses concern as to why SSP 12.3, Section 3.1.4, t
t
, was-not addressed in the incident investigation.
This section of SSP 12.3 and provides specific examples, such as megger tests and hydrostatic tests.
This guidance does not apply to the steps performed in this SI; therefore, the incident investigation appropriately did not address this concern.
In addition, TVA has evaluated the Staff's concern that the due dates for implementation of corrective actions were not timely since several diesel generator inspections were scheduled to be performed prior to these due dates.
As described in the inspection report, TVA provided specific training on this event for electrical maintenance personnel prior to performing the next diesel generator surveillance.
Based on this training and TVA's evaluation that the SI was correct and if properly implemented would have prevented this event, TVA has determined that the due dates listed in the incident investigation were adequate and timely.
This event was caused by inadequate training which resulted in plant personnel failing to utilize an approved plant procedure for transfer of material through the SFSP transfer canal.
Contributing to this event was a personnel error in which plant personnel failed to recognize a change in the work scope of an approved plant work order.
In this event, plant personnel were transferring spent filters from the Unit 2 SFSP to the Unit 1 SFSP through the transfer canal.
Plant personnel were utilizing an approved plant work order during the performance of this work.
- However, the work order did not address transfer of the spent filters between different SFSPs.
- Instead, the work order described a process of transferring the spent filters directly from each pool into the transport cask.
The decision to transfer the filters from the Unit 2 SFSP to the Unit 1 SFSP was based on as low as reasonably achievable considerations.
Plant personnel did not recognize that this was a change in the work method and that plant procedure 1/2-POI-78-1, v
't t
, was required to transfer non-fuel material through the transfer canal.
This event was identified when the transfer canal gates failed to seal when reinstalled after the transfer of the spent filters was completed.
This resulted in SFSP water leaking through the transfer canal gates.
TVA's review of this event has shown that sealing of the transfer canal gates was considered to be a,skill-of-the-craft activ'ity and was not addressed. in 1/2-POI-78-1.
Therefore, the use of this procedure would not have prevented the leakage from occurring.
Enclosure 1
Page 4 of 5 In addition, TVA's investigation into this event and discussions with General Electric (GE) personnel has shown that sealing of the SFSP transfer canal gate is based on the weight of the gates, the d'ifferential water pressure on the sides of the gate, and the condition of the gate seals.
The fact that the swing nuts on the gate seals were found to be hand tight, as di.scussed in the NRC inspection report, did not contribute to this event.
- Instead, leakage through these gates may normally be stopped by repositioning the gates or by replacing the gate seals if they show signs of wear.
The equipment clearance training program has been revised to include the ci'rcumstances of this event, and to provide specific emphasis that when a clearance is placed in an "equipment not aligned normal" configuration, Operations may, at their discretion, reposition the equipment as necessary.
Also, affected plant personnel have received sensitivity training concerning this event.
Specific emphasis was placed on the use of non-standard terminology and the importance of attention to detail.-
Additionally, TVA has enhanced the SI to include specific instructions
,on equipment alignment.
This event has been reviewed with GE and RADCON personnel involved in refuel floor activities to emphasize the use of 1/2-POI-78-1 to control transfer evolutions on the refuel floor and the importance of pre-job briefings.
Also, counseling was provided concerning the proper use and revision of work orders to ensure that personnel are aware of procedural requirements for changing the scope of approved work orders.
Finally, plant procedures that control SFSP operations have been revised to incorporate a reference to 1/2-POI-78-1 when transferring any material through the transfer canal.
TVA has also enhanced 1/2-POI-78-1 to provide directions for repositioning of the gate to ensure sealing and for inspection and replacement of the gate seals, if necessary.
t v t
t t v
k t
v No additional corrective steps are required for this event.
Enclosure 1
Page 5 of 5 b.
This event will be reviewed with Operations personnel involved in refuel floor activities to emphasize the use of 1/2-POI-78-1 to control transfer evolutions on the refuel floor and the importance of pre-job briefings.
This review will be completed by May 15, 1992.
TVA considers that full compli'ance will be achieved by May 15,
- 1992, when Operations review of the SFSP event is complete.
ENCLOSURE 2 Tennessee Valley Authority.
Browns Ferry Nuclear Plant (BFN) h Reply to Notice of Violation (NOV)
Inspection Report Number This event will be reviewed by Operations personnel involved in refuel floor activities by May 15, 1992.
This review will stress the importance of pre-job briefings and the use of 1/2-POI-'8-1.