ML18038B530
| ML18038B530 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/07/1995 |
| From: | Machon R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9511140182 | |
| Download: ML18038B530 (12) | |
Text
PKJ.OMJ-x x (ACCELERATED RIDS PROCESSING)
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RXDS)
CCESSION NBR:9511140182 DOC.DATE: 95/11/07 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 MACHON,R D.
Tennessee Valley Authority RECIP.NAME RECIPXENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Forwards response to NRC 951013 ltr re violations noted in insp repts 50-259/95-51,50-260/95-51
& 50-296/95-51.C/As:
eatablished multi-disciplined incident investigation team.
DISTRIBUTION CODE:
ZE01D COPIES RECEXVED:LTR ENCL SIZE:
TITLE: General (50 Dkt).-Insp Rept/Notice of Violation Response NOTES:
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05000259 P
05000260 05000296 RECIPIENT ID CODE/NAME PD2-3-PD INTERNAL: ACRS AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRPM/PECB OE DIR RGN2 FILE 01 EXTERNAL: LITCO BRYCE,J H
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1 RECIPIENT XD CODE/NAME WILLIAMS,J.
AEOD/DEIB AEOD T CARTER NRR/.DRCH/'
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0 NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE!
CONTACT THE DOCUMENT CONTROL
- DESK, ROOM OWFN 5DS (415-2083)
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LTTR 19 ENCL 19
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Teoressee vatey Au',rcrty. post 0 ce Sox 2GGG.
eca: r. Aamna 356G9 2cco R. D. (Rick) Machon Vce Pres~cot. Srovrr s Ferry Stvcear Pact November 7,
1995 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 10 CFR 2
,Appendix C
Gentlemen:
Zn the Matter of Tennessee Valley Authority Docket Nos.
50-259 50-260 50-296 BROWNS 'PERRY NUCLEAR PLANT (BPN) - NRC ZNSPECTZON REPORT 50-259'0-260i 50-296/95-52. - REPLY TO NOTZCE OP VZOLATZON (NOV)
Th'is. letter provides our reply to the subject NOV transmitted by letter from E.
W. Mershoff, NRC, to Oliver D. Kingsley, TVA, dated October 13, 1995.
This NOV involved a failure to properly log,foreign material on a foreign material accountability log.
TVA admits the violation.
We share NRC's concern that a foreign material condition has
- recurred, even after corrective actions were taken in the fall of 1994 as a result of previous events.
We also recognize the regulatory significance of this condition, especially in light of similar industry problems that have occurred due to foreign material in the suppression pools.
Because of this, we convened a multi-disciplined team to evaluate our existing controls and determine what changes
.should be made to our work practices.
From their recommendations, we have sensitized both TVA and contractor personnel to the need to control foreign material.
We have also identified other programmatic actions to strengthen our foreign material exclusion program.
These actions are discussed in more detail in the enclosure.
951'1140182
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U.S. Nuclear Regulatory Commission Page
.2 November 7,
1995 The enclosure provides our reply to the NOV. If you have any questions regarding this reply, please contact Pedro Salas at (205) 729-2636.
Sincerely, R.
D.
M on Site Vice President Enclosure, cc (Enclosure):
Mr. Mark S. Lesser, Branch Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323.
NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road
- Athens, Alabama 35611 Mr. J. F..Williams, Project.Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852
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ENCLOSURE TENNESSEE VALLEY AUTHORZTY BROWSES FERRY NUCLEAR PLANT (BFN)
UNITS 1g 2 g AND 3 INSPECTION REPORT NUMBER 50-259'0-260'0-296/95-51 REPLY TO NOTICE OF VIOLATION (NOV)
REST T
F E V 0 TZO 10 CFR 50, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be prescribed by procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures.
Foreign Material Exclusion Control, an activity which affects quality by preventing the introduction of foreign material into systems relied upon to safely operate and shutdown a nuclear power plant, is accomplished by implementing the requirements of Site Standard Practice SSP-12.8, Foreign Material Exclusion.
SSP-12.8 requires that foreign material, when taken into a Foreign Material Exclusion Zone, be recorded into the Foreign Material Exclusion accountability log to ensure proper tracking of the material until it is removed from the Foreign Material Exclusion Zone.
Contrary to the above, on August 30, 1995, while performing a walkdown of the torus interior, NRC inspectors determined that a temporary light stringer being utilized within the Foreign Material Exclusion Zone was not logged in the Foreign Material Exclusion accountability log.
This is a Severity Level IV Violation (Supplement I).
TVAiS REPL TO THE VIOLATION 1 ~
Back round During Unit 3 recovery, the Unit 3 torus was considered a
construction area, not a Foreign Material Exclusion (FME) area.
At that time, the torus was drained. with the torus ring header strainers capped to enclose the torus.
Based on this configuration,
.no FME accountability was required.
Following completion of the work activities, the torus was inspected, the strainers were uncapped, and the torus ring header was inspected and cleaned of some residue.
On April 21, 1995, the Unit 3 torus was turned over to the Unit 3 outage group to establish an FME area.
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preparation for pumping water into the torus, a
contamination zone was established on the torus catwalk.
In this contamination.,zone, many loose articles that were in the torus were placed on a 20-foot piece of herculite.
Later, two individuals entered the torus to remove the loose articles on the herculite.
The individuals identified these articles to the Foreign Material Exclusion Monitor (FMEM) as they were bagging them.
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at o This violation resulted from personnel error.
In this event, the FMEM became preoccupied with logging items that were being removed from the Unit 3 torus.
As a result, the FMEM did not enter the torus to perform the required baseline FME inventory.
- Instead, the FMEM incorrectly relied on the individuals'tatements that all FME was removed from the torus.
The performance of a baseline inventory was also overlooked.
on subsequent entries.
The FMEMs on the latter entries presumed a baseline inventory had been performed'nd focused on maintaining the ongoing inventory.
Consequently, the accuracy of the initial baseline was never questioned.
Correct e A t o s Taken And Results Achie d
As a result of this event, TVA established a multi-disciplined incident investigation team to investigate this event and establish corrective actions to prevent recurrence.
'The team also evaluated existing controls and determined what changes should be made to work practices.
From these recommendations, a single point of contact has been established for the FME Program with ultimate responsibility for the program.
TVA baselined the Unit 3 torus FME above the water line, and verified that.locks were installed on the torus to control access.
TVA had divers inspect the Unit 3 torus and torus ring header; some small items were discovered and removed.
The FMEM and the supervisor involved in establishing an FME area were counseled on the need to make an initial tour to ensure that an FME area is properly inventoried.
Crew meetings were conducted with Maintenance personnel to sensitize them to the need. for their increased awareness of the importance of FME control.
The BFN Plant.Manager also issued a site bulletin to plant employees.
This bulletin described this event> the cause of the event, the correct process to prevent recurrence, and his expectations for plant employees to correctly follow the process.
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Site Standard Practice (SSP) -12. 8, Foreign Material Exclusion, requires that Quality Assurance personnel perform an FME inspection prior to closeout of the torus FME area.
Consequently, TVA believes the light stringer identified in this violation would have been identified and removed during the final inspection of the torus.
Similarly, Unit 3 General Operating Instruction (GOI) 3-GOI-200-2, Drywell Closeout, specifies requirements for walkdowns of the Unit 3 drywell prior to drywell closeout.
As part of this GOI, each drywell elevation and the torus ri'ng header is walked down/inspected to ensure foreign material', including temporary fibrous material, is identified and removed.
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Corrective 8te s That Have Been Or Will Be Taken To Avoid Purther Violations TVA plans to revise FME training to include specific requirements for RADCON technicians, Chemistry technicians, Quality Control inspectors, work planners, Operations personnel, and contractors.
This training will include a section to emphasize each employee's responsibility in preventing foreign material intrusion and reporting any loss of FME control.
TVA also plans to revise the General Employee Training Program to emphasize the responsibility and authority of the FME monitors.
TVA expects to complete these actions by February 1,
1996.
TVA also plans to revise SSP-12.8 to implement the recommendations of INPO Significant Operating Experience Report, 95-1, Reducing Events Resulting From Foreign Material Intrusion.
This change will strengthen the procedure by specifying requirements for establishing large FME zones (e.g., torus, refueling, floor).
TVA expects to complete this procedure enhancement by December 1,, 1995.~
,Date When Pull Com liance Will Be Achieved TVA is in full compliance.
These actions are not regulatory commitments.
This procedure revision is not a regulatory commitment.
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