ML18036B115
| ML18036B115 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/28/1992 |
| From: | Zeringue O TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9301040186 | |
| Download: ML18036B115 (17) | |
Text
ACCELERATED DOCUMENT DISTRIBUTIONSYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) l ACCESSION NBR:9301040186 DOC.DATE: 92/12/28 NOTARIZED: NO" DOCKET
. FACI>: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 921127 ltr re violations noted in insp repts 50-259/92-37,50-260/92-37
& 50-296/92-37.Corrective actions:
personnel counselled on adherence to procedures.
DISTRIBUTION CODE:
ZE01D COPIES RECEIVED:LTR i
ENCL r
SIZE: /+
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
D A
RECIPIENT ID CODE/NAME HEBDON,F WILLIAMSIJ.
INTERNAL: ACRS AEOD/DEIB AEOD/TTC t
NRR MORISSEAUiD NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/PMAS/ILRB12 OE~JR Z~IIEE 02
~ EXTERNAL.
G&G B
- CE J.H.
NSIC COPIES LTTR ENCL 1
1 1
1 2
2 2
2 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 RECIPIENT ID CODE/NAME ROSS IT.
AEOD AEOD/DSP/TPAB DEDRO NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/PMAS/ILPB NUDOCS-ABSTRACT OGC/HDS3 RGN2 FILE 01 NRC PDR COPIES LTTR ENCL 1
1 1
1 1
=1.
1 1
1 1
1 1
2 2
1 1
1 1
1 1
1 1
D D
~D A
D NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACI'HE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
D TOTAL NUMBER OF COPIES REQUIRED:
LTTR 27 ENCL 27
Tennessee Valley Autnontyr Post Office Box 2000, Decatur, Alabama 35609.2000 O. J. "Ike" Zeringue Vice President. Browns Ferry Nuclear Plant DEC 28 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, 50-260, 296/92-37 AND 92-33 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 November 27, 1992.
In that letter, NRC cited TVA with three violations:
(1) failure to adhere to the requirements of the Fire Protection Program Plan, (2). failure to verify secondary containment isolation.during a surveillance test and (3) failure of a fire watch to remain attentive.
This third violation also addresses a previous example identified by the NRC in Inspection Report 92-33.
Enclosure 1 to this letter is TVA's "Reply to the Notice of Violation" (10 CFR 2.201).
A listing of commitments made in this letter is provided by Enclosure 2.
If you have any questions regarding this reply, please telephone G. D. Pierce at (205) 729-7566.
Sincerely, r/~//j'g 0". J. Zeringue 040036 Enclosures cc:
See page 2
9301040186 921228 PDR ADOCK 05000259 8
U.S. Nuclear Regulatory Commission DEC 28 t992 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
EHCLOSURE 1 Tennessee Valley Authority Browns Ferry Huclear Plant (BFH)
Reply to Hotice of Violation (HOV)
Inspection Report Humber 0-25 2 0 296 2-and 2-3 RESTA OF OLATIO 2-A.
"Technical Specification 6.8.1.l.f requires that written procedures shall be established, implemented, and maintained covering implementation of the fire protection program.
FPP-2, Fire Protection Attachments, is the controlling procedure which implements portions of this requirement concerning transient combustibles and fire watches.
I FPP-2, Attachment C, step 5.1.1 requires any combustible material that is not permanently installed be designated as a transient combustible and controlled by a transient combustible permit inspected,and signed daily by the responsible supervisor.
Step 5.2.5 further requires that all lumber used not designated as fire-retardant must be approved by the Fire Protection Engineering Section.
FPP-2, Attachment I, step 5.3.4 requires a continuous fire watch when "hot work", any work requiring torch cutting, welding, open-flame, grinding, or spark-producing operations, is performed in the plant areas.
Additionally the procedure requires the fire watch remain in the immediate work area for 30 minutes after the completion of all "hot work."
Contrary to the above, the requirements for FPP-2, Fire Protection Attachments were not met for the following five examples identified by HRC inspectors:
1.
On September 15, 1992, painting was observed in the Diesel Generator Building that was being controlled under transient combustible permit 92-0252 although the area had not been inspected nor the permit signed since September 10, 1992.
2.
On October 13, 1992, painting was observed in the Diesel Generator Building which was being controlled under transient combustible permit 92-0304 although the area had not been inspected nor the permit signed since October 8, 1992.
g
3.
On October 16,
- 1992, a four foot by eight foot sheet of untreated plywood was observed in Diesel Generator Room lA.
There was no transient combustible permit posted nor had Fire Protection Engineering approved its use.
4.
On October 22,
- 1992, a large storage box and two sawhorses made of untreated plywood were observed within the protected area near the maintenance building but were not controlled by a transient combustible permit.
5.
On October 21, 1992, welding was being performed without a continuous fire watch posted in a spark-producing area inside the turbine building.
This is a Severity Level IV violation (Supplement I) applicable to all three units.
B.
Technical Specification 6.8.1, Procedures, requires that written procedures shall be established, implemented and maintained covering surveillance and test activities of safety-related equipment.
Surveillance Instruction 3-SI-4.2.A-10, step 7.5.2.4 requires that unit 3 reactor zone be verified as isolated following initiation of a test signal.
Contrary to the above, these requirements were not met when on October 27,
- 1992, the Unit 3 reactor zone was not verified to be isolated during the performance of the surveillance instruction.
This coincident with failure of both exhaust dampers to close, resulted in the'potential for a radioactive release for 13.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.
This is a Severi'ty Level IV Violation (Supplement
- 1) applicable to all three units.
C.
Technical Specification 3.11.G.l.a, requires that with a required fire-rated sealing device inoperable, within one hour establish a
continuous fire watch on at least one side of the sealing device.
Implementing procedure for fire watches, FPP-2, Fire Protection
- Program, Attachment L, requires that the fire watch shall be on continuous alert for fire, signs of fire; and/or any act that might result in a fire.
Contrary to the above, on November ll, 1992 [sic November 4, 1992],
the licensee identified a fire watch established by Limiting Condition for Operation, 3-92-129.3.11.G, for an inoperable fire wrap located in Unit 3 reactor building, who was not on continuous alert and was inattentive in his duties.
This is another example of Severity Level IV Violation (Supplement I) issued in Inspection Report 92-33 dated November 2, 1992 and is applicable to all three Units."
TVA'S REPLY TO VIOLATIOHA l.
Reason for the Violation A a.
Failure to Pro erl Control Transient Combustibles Exam les 1
2 and These examples were a result of personnel failure to follow procedure.
Specifically, inspection for transient combustibles had not been performed as required by procedure.
Fire Protection Program Plan (FPP)-2, Attachment C, Paragraph 5.1.1 requires that in critical areas, such as the diesel generator building, any combustible material that is not permanently installed be designated as a transient combustible.
The responsible supervisor/foreman has the responsibility of ensuring that combustibles are properly controlled and that all requirements of permits are met.
b.
Stora e Box and Sawhorses in the Protected Area Exam le 4 C ~
FPP-2, Attachment C, Paragraph 5.1.1 states that combustible material located in critical areas that is not permanently installed be designated as a combustible load.
FPP-2 defines critical areas as the Reactor Building, the Diesel Generator Building, the Control Bay, the Intake Pumping Station E1,550 and cable tunnel to Turbine Building, and south wall of the Turbine Building E1.586.
Since the storage box and two sawhorses located near the maintenance building were not in a critical area, a transient combustible permit was not required.
Weldin 0 eration Without a Continuous Fire Watch Exam le 5
The welding activity was being performed using an approved permit.
TVA contract craft were installing a threshold in the doorway between the east wall of the turbine building and the newly erected east access portal.
A fire watch was posted on the access portal side of the turbine building exterior wall.
A partition covered the doorway between the turbine building wall and the not yet completed access portal.
At the beginning of the activity the responsible foreman did not realize sparks could enter the turbine building, but upon noting they could, stopped the work and established a fire watch.
The NRC identified this ongoing welding 'operation without a continuous fire watch inside the turbine building.
2.
Corrective Ste s Taken and Results Achieved a.
Failure to Pro erl Control Transient Combustibles The personnel involved in the activities leading to Examples 1
and 2 of this violation were counselled on adherence to procedures.
Also, the sheet of plywood in example 3 was removed from the Diesel Generator Building.
b.
Stora e Box and Sawhorses in the Protected Area The wood storage box and sawhorses were removed from the protected area as a precautionary measure.
c.
Weldin 0 eration Without a Continuous Fire Watch Upon determining that sparks from the welding operation could be entering the turbine building under the partition, the responsible foreman stopped the activity and established a fire watch on the Turbine Building side of the partition prior to resuming work.
3.
Corrective Ste s That have been or Will Be Taken to Avoid Further Violations a.
Failure to Pro erl Control Transient Combustibles TVA Maintenance established a single point of contact to be responsible for inspection of combustible load permits for painting activities.
Also, one person or designee has been assigned the responsibility for ensuring that the transient combustibles are controlled and the requirements of the permits are met.
Finally, affected personnel will be required to review a summary of Fire Protection Plans.
b.
Stora e Box and Sawhorses in the Protected Area No additional corrective actions are required.
c.
Weldin 0 eration Without a Continuous Fire Watch No additional corrective actions are required.
4.
Date When Full Com liance Will Be Achieved a.
Failure to Pro erl Control Transient Combustibles Full compliance will be achieved by March 1, 1993, when affected personnel have reviewed a summary of the Fire Protection Plans.
b.
Stora e Box and Sawhorses in the Protected Area TVA considers that full compliance has been achieved.
c.
Weld n 0 eration Without a Continuous Fire Watch TVA considers that full compliance has been achieved.
TVA'S REPLY TO VIOLATIO B
Reason For Violation B Surveillance Instruction (SI) 3-SI-4.2.A-10 generates a containment isolation test signal that initiates all three trains of the standby gas treatment
- system, control room emergency ventilation trains A and B, refueling zone isolation, Unit 3 group VI isolation, and isolation of the Unit 3 reactor zone.
These initiations/isolations were verified in Step 7.5.2 of 3-SI-4.2.A-10.
The SI does not state how to verify the Unit 3 reactor zone isolation is accomplished.
A Unit 3 operator used Zone Indicator (ZI) light, REACTOR ZONE ISOLATED, on control panel 3-9-25 to check for the reactor zone isolation.
(The ZI light does not supply adequate isolation verification and only indicates that the containment isolation test signal'ad been generated.)
If the operator had checked the damper position lights, he would have realized the reactor zone ventilation exhaust isolation dampers had failed to close.
Approximately 13.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> later, a unit operator noticed both red and green damper position indicating lights lit on control panel 3-9-25.
The Unit 3 reactor zone ventilation exhaust inboard isolation damper (3-FCO-64-42) was found in the intermediate open position and the outboard isolation damper (3-FCO-64-43) in the fully open position.
The failure of inboard isolation damper'o fully close is believed to have been caused by debris caught in the damper.
(This could not be conclusively determined.)
The failure of the outboard isolation damper to close was due to its air operated solenoid valve (3-FSV-64-43) sticking in the open position.
,(Preliminary examination of the solenoid operated valve (SOV) indicated failure may have been caused by a binding valve stem.)
2 ~
Corrective Ste s Taken and Results Achieved Both reactor zone inboard and outboard isolation dampers were manually closed.
The inboard damper flow control operators were disconnected and the damper was cycled and stroked freely by hand to fully closed position.
The outboard isolation damper was also manually closed by,isolating the air supply to the damper solenoid valve and bleeding air off the damper.
The outboard damper's SOV was replaced.
Personnel inspected the inboard damper and believe a piece of debris may have been caught in the damper holding it partly open.
Although additional debris was found and cleaned from the bottom of the ventilation duct, TVA was unable to recreate a binding problem in the damper.
TVA could not determine whether the debris was from initial construction or from later duct modification or repair.
3.
Corrective Ste s That have been or Will be Taken to Prevent Recurrence TVA will survey operators knowledge on the correct way to determine that secondary containment (i.e., reactor zone) is isolated.
Based on the results of this survey, operator training will be revised, if necessary, to provide greater emphasis on how to verify that an isolation has occurred.
The radiation monitor calibration and functional test SI will also be revised to better define what must be verified for the reactor zone to be considered isolated (i.e.,
to require damper position verification).
The preventive maintenance activity on secondary containment dampers will be revised to include an inspection for debris to reduce the risk of debris being caught in the dampers.
This is being done as a precautionary measure since TVA could not conclusively determine that debris was the cause of failure.
The failed outboard damper solenoid will be examined at a TVA laboratory and by the solenoid vendor to determine the cause of the failure.
Additionally, TVA will replace the secondary containment outboard damper solenoids.
4.
Date When Full Com liance Will Be Achieved Full compliance will be achieved when all of the following corrective actions are completed by July 30, 1993:
a.
Based on the results of TVA survey of operators'nowledge on the correct way to determine secondary containment, operator training will be revised, if necessary, to provide greater emphasis on how to verify that an isolation has occurred.
b.
Revise the radiation monitor calibration and functional test surveillance instruction to require damper position verification.
c.
The preventive maintenance activity on secondary containment dampers will be revised to include an inspection for debris.
d.
The failed outboard damper solenoid will be examined at a TVA laboratory and by the solenoid vendor to determine the cause of the failure.
TVA'S REPLY TO VIOLATION C AND NOV 2-33-02 l.
Reason For Violation C and OV 2-3 -02 Both violations were the result of individuals not complying with approved site procedures.
Fire protection procedure (FPP)-2, Attachment L, step 5.2, requires fire watches to be on continuous alert for fire, signs of fire and/or an act that might result in fire.
A contributing factor was that the corrective action from the first violation event which occurred on October 2, 1992, was not fully implemented.
To preclude future violations for inattentive fire
- watches, TVA was in the process of hiring, additional fire watches to limit overtime hours.
- However, these additional fire watch personnel were receiving required training when this event occurred.
2.
Corrective Ste s Taken and Results Achieved Personnel corrective actions for both events were taken as appropriate.
TVA provided a 4-hour training course to fire watches to assure that they are aware of their duties and the responsibilities of performing those duties.
This training emphasizes that fire watch personnel are accountable for their actions.
Additional fire watches were hired to limit the number of hours fire watches are required to work.
Fire watch foremen are now required to periodically tour fire watch areas to ensure fire watches are attentive.
Finally, fire watches are rotated hourly to enhance attentiveness.
3.
Corrective Ste s That have been or Will Be Taken To Prevent Recurrence No further actions are required to preclude recurrence of this type of violation.
4.
Date When Full Com liance Mill Be Achieved TVA considers that full compliance occurred-when appropriate personnel corrective actions were taken and additional fire watches were hired on November 5, 1992, to allow 8-hour shift schedules.
EHCLOSURE 2 Tennessee Valley Authority Browns Ferry Huclear Plant (BFH)
Reply to Hotice of Violation (HOV)
Inspection Report Humber 50-25 260 2 / 2-37 and 92-33
~l Commitments for Violation A Personnel will review a summary of the Fire Protection Plans by March 1, 1993.
2.
Commitments for Violation B A.
TVA will revise operator training by March 28, 1993, if necessary, to provide greater emphasis on how to verify that an isolation has occurred,.
This will be based on a survey result of the operators knowledge on the correct way to determine that secondary containment is isolated.
B.
TVA will revise the radiation monitor calibration and functional test surveillance instruction to require damper position verification for reactor zone isolation by February 15, 1993.
C.
TVA will revise preventive maintenance activity on secondary containment dampers to include an inspection for debris to reduce the risk of debris affecting damper operation by June 30, 1993.
D.
TVA will examine the failed 3-FSV-64-43 solenoid at its laboratory and will also have the vendor examine the solenoid to determine the cause of the failure.
This corrective action will be completed by July 30, 1993.