ML18037A516
| ML18037A516 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/18/1993 |
| From: | Zeringue O TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9310260075 | |
| Download: ML18037A516 (21) | |
Text
scen,Ka.mKD Docmvrmxr D>Sxjuamrow SvsxzM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9310260076 DOC.DATE: 93/10/10 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
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50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION ZERZNGUE,O.J.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 930917 lre re violations noted in Insp Repts 50-259/93-28,50-260/93-28
& 50-296/93-28.Corrective actions:
as of 930823,TVA implemented new program which integrates M&TE controls w/maint planning
& control sys.
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SIZE: I TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
REC1PIENT ID CODE/NAME PD2-4-PD WILLIAMSIJ.
INTERNAL: ACRS AEOD/DSP/ROAB AEOD/TTC NRR/DORS/OEAB NRR/DRIL/RPEB NRR/PMAS/ILPBl NUDOCS-ABSTRACT OGC/HDS3 RES/HFB EXTERNAL: EG&G/BRYCE,J.H.
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1 RECIPIENT ID CODE/NAME TRIMBLE,D AEOD/DEIB AEOD/DSP/TPAB DEDRO NRR/DRCH/HHFB NRR/DRSS/PEPB NRR/PMAS/ILPB2 OE DIR 02 82 FILE 01 NRC PDR COPIES LTTR ENCL 1
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NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACI'HE DOCUMENT CONTROL DESK, ROOM PI-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
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LTTR 25 ENCL'5
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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~
50 260'0 296/93 28 REPLY TO NOTICE OF VIOLATION (NOV)
On September 17, 1993, the NRC staff issued an inspection report (IR) which identified two violations.
The first violation cited a failure to comply with 10 CFR 50, Appendix B, Criterion XII, due to a lack of control of Measuring and Test Equipment (M&TE).
The second violation cited a failure to comply with Technical Specification 6.8.1.1.f due to recurring problems to control combustible material.
TVA's reply to the NOVs (10 CFR 2.201) is provided in Enclosure 1.
Your letter stated that these violations are similar to previous NOVs for M&TE and transient combustibles (i.e.,
NOVs 92-21 and 92-37, respectively).
Based upon our review of the
- issues, TVA acknowledges that our previous corrective actions were too narrowly focused on the specific issues that were individually identified.
As a result, they were not of a broad enough perspective to prevent the recurrence of the NOVs addressed in this IR.
We firmly believe that the actions in this reply are directed towards a clearly defined solution.
Due to the nature of these issues we have specifically allocated additional time to assess their effectiveness in preventing recurrence of these types of findings.
Therefore, for a six-month period TVA will jjogn) cP3 1026007>
05000259 5 931018 PDR ADOCH 8
U.S. Nuclear Regulatory Commission Page 2
0<5 i.8 )3K continue to provide increased management oversight of these
- issues, and may adjust the programs in order to maximize their effectiveness.
Additionally, your letter expressed the concern that our Quality Assurance (QA) organization has not been effective in identifying and/or correcting items of this nature.
While individual discrepancies were resolved in a timely manner following their identification, TVA did not fully assess their aggregate effect.
TVA notes that the QA organization had recognized M&TE and transient combustible deficiencies prior to these NOVs.
Furthermore, the QA organization fully recognized the need to initiate corrective action to address both areas.
Enclosure 2 offers details on both of these items.
Nevertheless, these violations have brought to our attention the need to bring to resolution those issues identified through our corrective action program in a more timely and aggressive manner.
Enclosure 2 desc.,-'bes the corrective actions being taken by the QA organi~
tion to address this issue.
l In addition, earlier this year, TVA recognize
.the need to improve its capabilities for trending of plan./problems.
To this end, TVA consolidated several groups into the
,Independent Review and Analysis (IR&A) organization.
This organization brings together data (internal and external to Browns Ferry) on potential areas of concern and technical expertise to evaluate these areas.
As part of the consolidation, TVA upgraded the technical qualifications of its members.
Among its duties, this organization will be evaluating and trending issues identified in Incident Investigations, QA audits, et al., to identify early symptoms of programmatic and/or implementation problems and to assess the need for process improvements.
Enclosure 3 contains commitments that are made in the reply.
U.S. Nuclear Regulatory Commission Page 3
J If you have any questions regarding this reply, please telephone Pedro Salas at (205) 729-2636.
Sine rely Zerxngue Enclosures cc (Enclosures):
Mr. R. V. Crlenjak, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, 'Alabama 35611 Mr. J.
F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. D.
C. Trimble, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852
ENCLOSURE 1
Tennessee Valley Authority Browns Ferry Nuclear Plant (BFN)
Reply to Notice of Violation (NOV)
Inspection Report Number 50-259 260 296 93-28 RESTATEMENT OF VIOLATION "During the Nuclear Regulatory Commission (NRC) inspection conducted on July 17 August 20, 1993, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C, the violations are listed below:
A.
10 CFR 50, Appendix B, Criterion XII requires that measures shall be established to assure that tools,
- gauges, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted to maintain accuracy within specif ied limits.
Site Standard Practice 6.7, Control of Measuring and Test Equipment, section 3.9, states that M&TE is to be checked out on a shift by shift basis unless the user records an expected return date on the usage log.
When M&TE is returned to the control area the usage log shall be updated to reflect the date returned, any additional uses, and the status of the M&TE.
Step 3.11.6.A states that if the M&TE is to be left unattended, the M&TE is to be tagged to identify the controlling document and the responsible individuals.
Contrary to the above, these requirements were not met for the following four examples identified by an NRC inspector:
On July 27,
- 1993, M&TE was in the unit generator building that was not tagged and was logged as having been returned area.
1 diesel as unattended to the control 2.
On July 28,
- 1993, M&TE was in the unit generator building that was not tagged and was logged as having been returned area.
3 diesel as unattended to the control
3.
On August 4, 1993, three pieces of M&TE had been checked out for a period exceeding that which was allowed without the proper documentation in usage log.
4.
On August 4,
- 1993, M&TE was located in the control area but due to mistakes in the usage log was believed to still be in use.
This is a Severity Level IV Violation (Supplement I) applicable to all three units.
Technical Specification 6.8.1.1.f, requires that written procedures shall be established, implemented, and maintained covering implementation of the Fire Protection Program.
Section I-C of the Fire Protection Report Volume 2, step 5.1.1, states that in critical areas, any combustible material that is not permanently installed shall be designated as a transient combustible.
Furthermore, the responsible supervisor/foreman shall initiate a transient combustible permit as required by this procedure and obtain Fire Protection Operations approval.
The permit shall be posted in the vicinity of the transient fire load until the fire load is removed.
Contrary to the above, these requirements were not met when on July 29, 1993, the inspector identified six reels of electrical cable, containing an amount of combustible material in excess of that allowed, located in the unit two reactor building, without a transient combustible permit and compensatory measure having first been established.
This is a Severity Level IV Violation (Supplement I) applicable to all three units."
-3 TVA's Re 1
to Violations A and B
VIOLATION A 1 ~ Reason For Violation A This event was the result of insufficient controls in the Measuring and Test Equipment (M&TE) program.
The program was previously controlled through a cumbersome tracking system.
The inconsistencies noted in the NOV created no significant adverse impact on plant operations, if considered individually.
- However, TVA recognizes that the aggregate effect of the M&TE deficiencies are indicative of a program weakness.
As indicated, TVA considers that the problem centered around the method for controlling M&TE (i.e.,
a manual tracking system).
The system lacked the capabilities for providing reliable information on M&TE issued for use and not returned.
Additionally, a computerized system was used to track calibration of M&TE.
The use of the two systems further aggravated the problem since the lists would not always agree.
Additionally, the M&TE system failed to provide an accountability to ensure that M&TE was returned by the end of each shift to the issue station.
At the time of the event, craft personnel were keeping M&TE in the field for up to seven (7) days.
This extended time frame prevented the effective control,of M&TE, and the verification of M&TE usage in a timely manner.
2 ~ Corrective Ste s Taken and Results Achieved Prior to the identification of the issues described in this
- NOV, TVA had recognized the weaknesses in the existing program and had initiated actions to procure a system designed to provide positive tracking of M&TE.
As of August 23,
- 1993, TVA implemented a new program which integrates M&TE,controls with the Maintenance Planning and Control (MPAC) system.
This greatly improves the ability to not only track the issuance of METE, but also the individual to whom M&TE was issued, where it was used, and when it was last calibrated.
This program includes a bar code system which will automatically update a
computer that tracks the calibration, out-of-tolerance (OOT)
M&TE, and the daily usage of M&TE.
In addition to the above action, an M&TE baseline inventory has been performed.
Unaccounted M&TE (i.e.,
41 of the approximately 4000 items) were placed in the "not on file" status.
This status has been entered in the computer to ensure that an M&TE item could not be returned to the system without being challenged.
Additionally, OOT investigations have been initiated for unaccounted M&TE.
Furthermore, delinquent M&TE is currently being reported on a weekly basis in the plan-of-the-day meeting.
This reporting mechanism clearly focuses senior plant management's attention on identified deficiencies.
M&TE is also being tracked by work orders that have a bar code.
This bar code will ensure that the M&TE can be confirmed during the closure process of the work order.
Finally, the MPAC system will automatically identify M&TE that, is not returned to the issue station on time.
This automated feedback will ensure accountability and a timely verification of M&TE usage in accordance with procedural requirements.
- 3. Corrective Ste s That have been or Rill Be Taken To Prevent Recurrence TVA believes that the above corrective actions will preclude recurrence of this type of violation.
As noted in the cover letter, the effectiveness of these corrective actions will be assessed during a six-month period.
TVA may make additional changes during that period in order to further improve the effectiveness of the M&TE program.
- Thus, TVA will be in full compliance by April 15, 1994.
VIOLATION B Reason for Violation B Failure to'- Pro erl Control Transient Combustibles The cause of this event was a lack of awareness and failure to properly implement the program for control of transient combustibles.
~
'he Fire Protection Report (FPR),
Volume 2, Section I-C, "Control of Transient Combustibles" requires that in critical areas (e.g.,
Reactor Building, Diesel Generator Building, Control Bay),
any combustible material that is not permanently installed shall be designated as a transient combustible and a
transient combustible permit shall be posted.
Furthermore, the responsible supervisor/foreman has the responsibility of ensuring that combustibles are properly controlled and complying with the requirements of the permit.
The individuals involved in this violation were not aware that electrical cable insulation constituted a transient combustible.
Corrective Ste s Taken and Results Achieved Once the need for a Transient Combustible Load Permit was recognized, a permit was issued and a firewatch was established..
The firewatch remained in place until the job was completed.
TVA recognizes that the actions leading to this violation were not isolated in nature, but were indicative of a weakness in the implementation of an established program to control transient combustibles.
Previous corrective actions initiated to address these types of concerns were focused on programmatic problems.
When a review was conducted of the entire scenario, including QA s involvement in each step, it became apparent that the true root cause was a failure to establish individual and first line supervisor accountability for adherence to the existing programs.
Although it is recognized that procedural/programmatic enhancements can aid individuals in the program implementation, the desired results will only be achieved when clearly defined expectations are disseminated to all individuals and then hold those individuals accountable for their actions.
Therefore, the following corrective actions, and those listed in Section 3 below, are directed toward improving individual awareness and modifying personnel behavior regarding transient combustibles:
(2)
The Technical Support organization is conducting walkdowns of critical plant areas with emphasis on housekeeping and transient combustibles.
Deficiencies are documented, brought to the immediate attention of the responsible organization, and appropriate corrective actions are initiated up to and including disciplinary action when appropriate.
On September 22, 1993, the plant manager issued a
memorandum to all plant employees noting the recurring problems with the control of transient combustibles.
Specifically, this memorandum noted that this problem is an embarrassment to BFN and further noted that the cooperation of everyone'is required to solve this problem.
(3)
TVA has issued information on this event to Engineering Support personnel as part of their annual continuing training.
- 3. Corrective 8te s That have been or Will Be Taken To Avoid Further Violations In order to heighten personnel awareness of the significance of transient combustibles in the work place, TVA will provide training to affected personnel.
Dedicated personnel have been selected to train affected TVA and contractor personnel as to their responsibility and accountability for the control of transient combustibles in the work place.
TVA will revise Site Standard Procedure 12.7 "Housekeeping/
Temporary Equipment Control." This revision will emphasize the need to be more cognizant of transient combustibles during housekeeping inspection activities.
Also, this revision will stress the need to abide by the Transient Combustible Load program during work activities.
TVA will consolidate the responsibility for administration and implementation of the Transient Combustible Load Program under the Technical Support organization.
TVA will revise
The revised procedure will strengthen the tracking and accountability of transient combustibles.
Further, until a level of confidence is restored in our ability to control transient combustibles, Nuclear Assurance and Licensing (NA&L) personnel will conduct a weekly walkdown of the plant and report the results directly to the Plant Manager.
Any failure to demonstrate an improving trend will be reported directly to the Site Vice President.
- 4. Date When Full Com liance Will Be Achieved By December 30,
- 1993, TVA will complete the actions described in Section 3 above.
- However, as noted in the cover letter, the effectiveness of these corrective actions will be assessed during a six-month period.
TVA may make additional changes during that period in order to further improve the effectiveness of the transient combustible program.
- Thus, TVA will be in full compliance by June 15, 1994.
ENCLOSURE 2
Tennessee Valley Authority Browns Ferry Nuclear Plant (BFN)
Reply to Concerns Identified in the Cover Letter to Notice of Violation (NOV)
Inspection Report Number 50-259 260 296 93-28 Introduction As indicated in the cover letter, NRC expressed a concern that TVA's Quality Assurance (QA) organization has not been effective in identifying and/or correcting the items addressed in the NOVs. It should be noted that, prior to the issuance of the NOVs cited in this Inspection Report (IR) and those addressed in previous IRs, deficiencies in the control of M&TE and transient combustibles have been identified by QA and progressive actions taken via TVA's Site Corrective Action Program.
A Identification of These Issues In the case of M&TE, this IR notes that problems with the control of M&TE were identified in July 1991 during a
QA audit and documented in CAQR BFSCA910168107.
Due to numerous findings identified in March/April 1993, QA initiated an assessment of the interim corrective actions regarding the control of M&TE.
This included evaluating the new M&TE MPAC program as addressed in our reply to the first NOV.
In the case of transient combustibles, QA has continued to assess this area during annual fire protection audits and followup assessments.
During these audits, transient fire load conditions were identified and immediately rectified.
- However, because of recurring problems in this area, QA issued a Finding Identification Report (BFFIR 930016306) in April 1993, due to numerous/recurring QA observations of transient combustibles without the required permit.
A Assessment of These Issues In retrospect, while the QA organization effectively identified and reported to site management the individual deficiencies in the areas of M&TE and transient combustibles, the actions to implement recurrence controls were not timely nor effective.
As periodic QA assessments were performed to ensure interim corrective actions were being implemented, additional problems continued to be identified and added to the existing corrective action documents.
- Further, increases in staffing levels and/or
work activities (e.g.
- outages, construction activities) placed sufficient burden on the programs to the extent that implementation deficiencies resurfaced without detection by the line organizations.
As a result, performance and the effectiveness of corrective actions/recurrence controls have been cyclic.
QA management had assessed these issues individually and determined that the additional problems did not adversely affect the safe operations of the plant.
- Thus, no finding was determined to be significant in nature to warrant additional escalation of the issues to senior management in order to expedite implementation of corrective actions.
As a result, QA was not fully effective in recognizing the aggregate effect of the findings on the M&TE program, and that the transient combustible problems were not a programmatic issue but an ineffective implementation process.
Corrective Actions Bein Taken In order to enhance the sensitivity to untimely and/or t
ineffective QA issues, the Site QA organization has taken the following initiatives:
o The Site NA&L manager will personally review all QA Unit 2 and common initiated corrective action documents greater than six months old to determine if escalation is warranted.
o The scope of the next deficiencies/corrective actions program audit has been revised to include review, evaluation, and status of identified corrective action items over one year old.
This audit is scheduled to begin on October 18, 1993.
o The Site Corrective Action Program (SSP-3.4) has been revised to follow-up closed SCARs within one year of the closure date to evaluate the effectiveness of corrective actions and verify that the root causes have been accurately identified and corrected.
o Site Nuclear Assurance (NA) personnel
.have been trained and management expectations reaffirmed regarding formal escalation of adverse conditions and quality issues (including untimely/ineffective results) to progressively higher levels of management.
This process is formally established in Quality Methods Procedure 116.1.
o The manager of the Site Condition Adverse to Quality program has been assigned the responsibility to establish a
historical record for senior management review for input to decisions concerning extension of due dates for Corrective Action program documents.
This history will include information concerning the original date the problem was identified, number of extensions previously approved, and reasons for previous 'approvals.
Additionally, NA personnel have been sensitized to validate the quality of extension justifications and ensure adequate interim actions are in place if immediate corrective actions are not feasible.
o As previously noted in our reply, the effectiveness of the corrective actions to prevent recurrence of the NOVs for M&TE and transient combustibles will be evaluated during a six-month period.
During this period, QA will also conduct an independent assessment of the M&TE and transient combustible programs.
0 ENCLOSURE 3
Tennessee Valley Authority Browns Ferry Nuclear Plant (BFN)
Reply to Notice of Violation (NOV)
Inspection Report Number 50-259 260 296 93-28 COMMITMENTS 1 ~
2.
3
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TVA will provide training to affected modifications personnel on the revised Transient Combustible Load Program by November 30, 1993.
TVA will provide training to other affected staff personnel on the revised Transient Combustible Load Program by December 30, 1993.
TVA will consolidate the responsibility for the requirements of the Transient Combustible Load Program under the Technical Support organization by November 30, 1993.
4
~
5.
TVA will revise Site Standard Practice 12.7 "Housekeeping/Temporary Equipment Control."
The revised procedure will be in place by November 30, 1993.
TVA will revise
The revised procedure will be in place by November 30, 1993.
6.
Until a level of confidence is restored in our ability to control transient combustibles, Nuclear Assurance and Licensing (NA&L) personnel will conduct a weekly walkdown of the plant and report the results directly to the Plant Manager.
This action is expected to be completed by December 30, 1993.
7
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The Site NA&L manager will personally review all QA Unit 2 and common initiated corrective.action documents greater than six months old to determine if escalation is warranted.
This action will be completed by November 30, 1993.
8.
The QA organization will conduct an independent assessment of the M&TE and transient combustible programs.
This assessment will be completed by April 15, 1994 for the M&TE program and by June 15, 1994 for the transient combustible program.