ML18036B315
| ML18036B315 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/01/1993 |
| From: | Zeringue O TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9306100336 | |
| Download: ML18036B315 (11) | |
Text
ACCELERATED DOCUMENT DISTRIBUTIONSYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CCESGION NBR:9306100336 DOC.DATE: 93/06/01 NOTARIZED:
NO DOCKET ¹ 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.h Tennessee Valley Authority RECIP.NAME RECIPIENT AFFZLIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC ltr re violations noted-in insp repts 50-259/93-12,50-260/93-12
& 50-296/93-12 on 930312-0416.
Corrective actions:instruct personnel
& replaced P-K block cover.W/930601 ltr.
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TITLE: General (50,Dkt)-Insp Rept/Notice of Violation Response-NOTES:
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PLEASE HELP US TO REDUCE WASTEI CONTACI'HE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
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Tennessee Valley Authority, Post Office Box K00. Decatur, Alabama 35609.2000 O. J. "Ike" Zeringue Vice President, Browns Perry Nuclear Plant JUN Oi 1993 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, 296/93-12 REPLY TO NOTICE OF VIOLATION (NOV)
On April 30,
- 1993, the NRC Staff issued a Notice of Violation (93-12) involving two examples of failure to comply with procedural requirements for equipment tagging.
While TVA does not contest the violation, TVA requests that NRC give consideration to reclassifying the violation as a
TVA makes this request for two reasons.
- First, TVA considers that the condition created by the five tags attached to fuse blanks found laying inside a panel is of minor safety significance.
- Second, TVA respectfully disagrees with the Staff that the use of the word "PLACED" for two hold order tags did not correctly specify the position of the P-K block covers.
TVA believes the word "PLACED" is an appropriate terminology and is consistent with BFN's training for tagging of P-K blocks.
The enclosure to this letter provides additional details for TVA's position.
Although TVA disagrees with the Staff on the enforcement aspects of these conditions, TVA acknowledges that both conditions required additional TVA attention.
In both cases, TVA has used the Staff's observation to improve the methods for tagging fuse blanks and P-K blocks.
9306i00336 930601 PDR ADOCK 05000259 8
J.S.
Nuclear Regulatory Commission JUN 0'1 1993 The enclosure also provides TVA's "Reply to the Notice of Violation" pursuant to the provisions of 10 CFR 2.201.
If you have any questions regarding this reply, please telephone Pedro Salas at (205) 729-2636.
Sincerely,
- 0. J. Zeringue 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 U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
EHCLOSURE Tennessee Valley Authority Browns Ferry Huclear Plant (BFH)
Reply to Notice of Violation (HOV)
Inspection Report Number
-25 260 2
-12 RESTA OF VIOLATIO "During the Nuclear Regulatory Commission (NRC) inspection conducted on March 12 April 16,
- 1993, 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.l.l.a, 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 covering equipment control (e.g. locking and tagging).
Site Standard Practice 12.3, Equipment Clearance Procedure, requires clearances involving control fuses located on multiple fused terminal boards that are required to be tagged shall have the control fuses
- removed, a hold notice tag attached to fuse blanks, and the fuse blanks inserted into the fuse clips.
Also, required is that each hold notice shall specify the component's positional condition on the clearance sheet.
Contrary to the above, these requirements were not met for the following two examples:
l.
On March 30, 1993, the inspector identified five instances of hold order tags not in place with the clearances still active.
The inspector found five tags attached to fuse blanks laying inside a
control room back panel cabinet while craft were working in the panels.
2.
On April 12,
- 1993, the inspector identified two hold order tags dn clearance number 3-93-0045 that did not correctly specify the component's position/condition on the clearance sheet.
The clearance sheet specified the position of PK block covers as "PLACED" but the block covers were removed and laying on the floor with the tag attached.
This is a Severity Level IV Violation (Supplement I)."
RE VEST FOR RECONSIDERATION TVA does not contest this violation; however, based on the reasons described
- below, TVA requests that NRC give consideration to reclassifying the violation as a Severity Level V (Supplement I).
Section D of Supplement I to the Enforcement Policy (1992) provides four examples of violations that may be classified at Severity Level IV.
Of these, only Example D.3, "[a] failure to meet regulatory requirements that have more than minor safety or environmental significance," reasonably could have been used by the NRC to classify this violation as Severity Level IV.
The corresponding, and only, example of a Severity Level V, classification in Supplement I is reserved for "[v]iolations that have minor safety or environmental significance."
- Further, Section 6.1.1 of the NRC Enforcement Manual provides for the classification of a violation at Severity Level V if that violation "involves the performance of work by a craftsman resulting in a clearly minor, isolated concern."
TVA believes Example 1 meets both criteria.
This event occurred during the Unit 2, Cycle 6 refueling which involved extensive modifications such as Control Room design review.
As indicated in Section II of this reply, TVA believes that this incident was isolated in nature and was due to the fuse blanks, with the hold order tags attached, being inadvertently dislodged in a congested area.
As noted, no additional dislodged hold order tags in the Unit 2 Control Room were discovered.
- Further, the relative significance of the five dislodged tags is minor when considering that approximately 30,000 tags were placed during the outage.
Additionally, equipment isolated using the equipment clearance procedure ensures the protection of personnel and plant equipment during operations, maintenance, and modification activities.
Electrical clearances are accompanied by removing the source of energy.
These clearances are numbered and a tag is placed on the affected equipment.
In addition, the equipment's position is recorded.
This portion of the process is independently verified according to procedure. 'he clearance remains intact until the work is complete, and a release of the clearance is requested.
Even though the tags were not in the ideal position, the equipment was deenergized as required by the clearance.
Therefore, based on the above
- summary, TVA concludes that Example 1 of the violation is.
a "minor, isolated concern."
Accordingly, TVA believes that this example should be classified as Severity Level V (Supplement 1) based on NRC guidance.
~
As indicated in Section III below, TVA respectfully disagrees with the NRC regarding Example 2 of the violation.
TVA considers that
. the tagging methodology used in this example is consistent with standard BFN practice, operator training, and procedures.
Additionally, it is noteworthy that TVA management personnel also took prompt responsive actions when notified of the events described in this example.
Furthermore, TVA has implemented procedural enhancements to preclude the potential for future recurrence of this type event.
II. REPLY TO VIOLATIONEXAMPLE 1
- 1. Reason for Violation The primary cause of this event was the design of the fuse blanks which permitted the five blanks to be dislodged in a congested area.
The fuse blank is a plastic piece which has four different sized cylindrical extensions.
These extensions are designed to fit in four different sized fuse holders.
Each cylindrical extension is designed to fit in only one of the two fuse holder clips.
The other cylindrical extensions protrude from the fuse holder.
This design, although adequate for normal traffic, can be easily dislodged when multiple personnel are required to work in a confined space such as Control Room back panels.
A contributing factor to this event is the failure of personnel working in the Control Room back panels to notify the Shift Operations Supervisor (SOS) when the five fuse blanks became dislodged.
During this refueling outage the Unit 2 Control Room has been undergoing major Control Room Design Review (CRDR) and integrated computer systems modifications.
These modifications required numerous personnel to be working in and behind Control Room panels.
It was during this time when the fuse blanks became dislodged from their assigned component.
TVA has not been able to identify the specific personnel who dislodged the fuse blanks or the length of time the fuse blanks were not in their assigned location.
2.
Corrective Steps Taken and Results Achieved Operations management immediately contacted the Plant Maintenance and the Modification supervisors to instruct their personnel to immediately stop work and notify the SOS if any additional fuse blanks were dislodged.
Personnel working behind panels were counselled on the importance of reporting to the SOS any fuse blanks not in their required position.
e An immediate Control Room board walkdown was conducted by licensed operators to ensure no other fuse blanks were missing.
Additionally, Operations personnel investigated if there were any additional hold order tags which were detached from their assigned component.
This investigation did not reveal any additional dislodged hold order tags.
Routine inspections of the back panels were instituted for the remainder of CRDR work.
Operations personnel have purchased dowels that will serve as fuse blanks on future hold orders where the personnel traffic is expecte'd to increase significantly.
These dowels are designed such that there are no protruding parts when properly positioned in the fuse holder.
The use of the dowels will be determined by the Operations tagging group based on the confinement and congestion expected in the area when the fuse is pulled.
The dowels are expected to preclude future recurrences of this type event.
Additionally, general employee training (initial and retraining) instructs plant personnel of their responsibility to notify the SOS or their supervisor if a hold order tag is found dislodged from its assigned component.
3.
Corrective Steps That [have been or] Will Be Taken To Prevent Recurrence TVA believes that the actions described in the preceding paragraph should preclude a recurrence of this type of event.
a 4.
Date When Full Compliance Will Be Achieved TVA considers that full compliance has been achieved.
III~ RBPLY TO VIOLATIO EXAMPLE 2 1.
Reason for Violation TVA respectfully disagrees with the NRC staff.
TVA considers that the description used to specify the position of the P-K'lock covers was consistent with BFN practice.
Nevertheless, as a result of NRC's observation, TVA identified that the process of tagging P-K block covers should be improved as described in Section 2 below.
When TVA receives a request from the Wilson load dispatcher (WLD), an offsite load dispatcher, to remove a P-K block cover from its stationary component, and when operators tag out a P-K block, they normally attach a hold order tag to the cover and remove the cover from the block.
Additionally, the word "PLACED" is written in the "position/condition" column on the clearance request.
This is BFN's standard practice and is consistent with the training provided to the operators for tagging these components.
The methodology for tagging P-K block covers was investigated and determined to be appropriate.
The terminology of "PLACED" was acceptable because it was the term commonly used for P-K blocks in this condition. It is noteworthy that the unit operator who wrote the clearance is the operator training instructor who teaches Reactor Operators and Senior Reactor Operators proper methods to tag switchyard components.
Upon further review of P-K block tagging, TVA identified an enhancement to the methodology.
Both plant personnel and the WLD tag P-K block covers.
WLD also repositions, though not on a hold order, P-K block covers for the relay protection desired.
A scenario could be postulated where plant personnel tagged a cover and the WLD, while changing relay protection, could replace the P-K cover.
As a result of this potential condition, the tagging methodology was changed to tag the stationary part.
2.
Corrective Steps Taken and Results Achieved TVA has taken the following corrective actions to ensure a
system which has been tagged out for maintenance is not inadvertently energized due to replacement of the P-K block cover.
(1)
The affected hold order tags were removed from the P-K block covers and attached to the stationary component of the P-K blocks.
=(2)
Site Standard Practice (SSP) 12.3, Equipment Clearance Procedure, step 3.1.5.B, was revised on April 26,
- 1993, to include a note requiring that hold order tags be attached to the stationary component of the P-K block.
3.
Corrective Steps That [have been or] Will Be Taken To Prevent Recurrence TVA believes the revision to SSP-12.3, step 3.1.5.B, should preclude recurrence of this type event.
4.
Date When Full Compliance Will Be Achieved TVA considers that full compliance has been achieved.
Ij