ML18036A904
| ML18036A904 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/13/1992 |
| From: | Zeringue O TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9210200241 | |
| Download: ML18036A904 (12) | |
Text
ACCELERATED TRIBUTIONDEMO RATION SYSTEM REGULATO~ INFORMATION DISTRIBUTION YSTEM (RIDS)
ACCESSION NBR:9210200241 DOC.DATE: 92/10/13 NOTARIZED: NO DOCKET 4
CIL: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 920911 ltr re violations noted in insp repts 50-259/92-29,50-260/92-29 a 50-296/92-29 on 920718-920814.
Corrective actions:provided supplemental training for affected personnel holding clearance authorization.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
RECIPIENT ID CODE/NAME HEBDON,F WILLIAMSiJ.
INTERNAL: ACRS AEOD/DEIB AEOD/TTC NRR MORISSEAUgD NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NUDOCS-ABSTRACT OGC/HDS3 RGN2 FILE 01 EXTERNAL: EGSG/BRYCE,J.H.
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1 RECIPIENT ID CODE/NAME ROSS,T.
AEOD AEOD/DSP/TPAB DEDRO NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/PMAS/ILRB1 2 OE G PZBE 02 NRC PDR COPIES LTTR ENCL 1
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1 NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE O'ASTE! CONTACT THE DOCUMENT CONTROL DESK.
ROOM PI'-~7 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 25 ENCL 25
Tertrtessr,'e Valley Authority. Post Oflice Box 2000. Decatur, Alabama 35609 OCT l3 1992 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, 296/92-29 REPLY TO NOTICE OF VIOLATION (NOV)
This letter provides TVA's reply to the NOV transmitted by letter from E.
W. Merschoff to M. 0. Medford dated September ll, 1992.
In this
. letter, NRC cited TVA with a violation involving one example of a failure to follow procedure.
In addition, NRC further states that "the violation is of concern because of the repetitive errors of modification contractor supervisors concerning hold orders."
TVA shares the staff's concern with respect to errors involving hold orders.
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 G.
D. Pierce at (205) 729-7566.
Sincerely,
( gAFiF(A
- 0. J. Zeringue Enclosures cc:
See page 2
9210200241 921013 PDR ADOCK 05000259 8
PDR g~g I
U.S. Nuclear Regulatory Commission OCT 13 1992 Enclosures cc (Enclosures):
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 1 Tennessee Valley Authority Browns Ferry Nuclear Plant (BFN)
Reply to Notice of Violation (NOV)
Inspection Report Number 50-25 260 2 6/ 2-2 RESTATEMENT OF VIOLATION "During the Nuclear Regulatory Commission (NRC) inspection conducted on July 18-August 14,
- 1992, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
Technical Specification Section 6.8.1, Procedures, requires that written procedures shall be.established, implemented and maintained covering the applicable procedures recommended in'Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Included in the appendix are administrative procedures for equipment control.
Site Standard Practice 12.3, Equipment Clearance Procedure, requires that personnel be signed onto a clearance prior to commencing work.
Contrary to the above, these requirements were not met when on July 29,
- 1992, a contractor supervisor completed work associated with Work Plan 3169-92 and failed to have clearance request 3-92-277 assigned to him by the Shift Operations Supervisor prior to commencement of the work activities.
This is a repeat Severity Level IV Violation (Supplement 1) applicable to all three units."
(g TVA RESPONSE TO THE VIOLATIO Reason for the Violation This violation was the result of a lack of attention to procedural requirements.
Site Standard Practice (SSP) 12.3 requires the clearance holder to request the Shift Operations Supervisor (SOS) or his representative to issue a clearance.
Contrary to the above, on July 28, 1992, after a satisfactory walkdown of the clearance boundaries and after obtaining a copy of the clearance sheet from Unit 3 Operations work control, the job supervisor failed to request the SOS to issue the clearance, to him prior to allowing work to begin.
Contributing to this event were differences that existed in the processes for obtaining clearances related to Unit 2 and Unit 3.
Specifically, issuing a clearance for recovery activities on Unit 3 requires the approval of Unit 3 Operations work control and the SOS.
These approvals are obtained from two separate locations.
In
, contrast, a clearance is issued for Unit 2.activities from a single location in the plant.
2.
Corrective Ste s Taken and Results Achieved Personnel corrective actions were taken as appropriate.
3 ~
Corrective Ste s that have been or will be Taken to Prevent Recurrence TVA has provided supplemental training for affected personnel holding clearance authorization.
This training included a
practical exercise, a requalification
- exam, and is now part of the annual requalification for these personnel.
In addition, TVA's investigation showed that contractor personnel not involved in e'xercising the equipment clearance procedure regularly exhibit varying degrees of knowledge of the process.
Accordingly, controls have been established to remove contractor personnel from the clearance list if individuals have been on the list for more than ninety days without holding a clearance.
This additional control will remain in effect until TVA considers that contractor personnel have sufficient experience to maintain a
consistent knowledge level.
Finally, to enhance the work sign-on process, TVA will provide facilities at a single location to provide clearance and work sign-on authorization for recovery activities affecting Unit 3.
TVA expects these facilities to be operational by December 17, 1992.
Date Mhen Full Com liance Mill Be Achieved TVA considers that full compliance will be achieved by December 17,
- 1992, when the additional facilities have been completed to obtain clearances for recovery activities affecting Unit 3.
"~
ENCLOSURE 2 Tennessee Valley Authority Browns Ferry Nuclear Plant (BFN)
Reply to Notice of Violation (NOV)
Inspection Report Number 50-25 260 296/92-29 COMMITMENT TVA will provide facilities at a single location to provide clearance and work sign-on authorization for.recovery activities affecting Unit 3.
TVA expects these facilities to be operational by December 17, 1992.
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