ML18038B692

Provides Response to Violations Noted in Insp Repts 50-259/96-03,50-260/96-03 & 50-296/96-03.Corrective Actions: Appropriate Steps of Procedure Signed

ML18038B692
Person / Time
Site:	Browns Ferry
Issue date:	05/14/1996
From:	Machon R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9605200433
Download: ML18038B692 (12)

Text

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

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ACCESSZOPJ NBR:9605200433'OC.DATE:

96/05/14 NOTARIZED: NO DOCKET I ACYL: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 MACHONIR.D.

Tennessee Valley Authority RECIP. NAME RECIPIENT 'AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Provides response to violations noted in Insp Repts 50-259/96-03,50-260/96-03 a 50-296/96-03.Corrective actions:

appropriate steps of procedure signed.

DISTRIBUTION CODE:

IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:

RECIPIENT ID CODE/NAME PD2-3-PD INTERNAL: ACRS AEO LE CE T NRRjDFCH HHFB NRR/DRPM/PERB t

OE DIR RGN2 FILE 01 EXTERNAL: LITCO BRYCE,J H

NRC PDR COPIES LTTR ENCL 1

1 2

2 1

1 1

1 1

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1 1

1 RECIPIENT ID CODE/NAME WILLIAMS,J.

AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS3 NOAC COPIES LTTR ENCL 1

1 1

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D NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!

CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SD-5(EXT. 415-2083)

TO ELIMINATE YOUR NAME FROM l

DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 19 ENCL '9

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Tenoessee va'ley Authority, post otrice Box 2000. DecaturAatta~ 35609.2000 R. D. (Rick) Machott Vice Presttteitt. Browns Ferry Near Ptartt May 14, 1996 U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.C.

20555

Dear Sir:

10 CFR 2 Appendix C

BROWNS FERRY NUCLEAR PLANT (BFN) - NRC ZNSPECTZON REPORT 50-259'0-260'0-296/96-03

- REPLY TO NOTICE OF VIOLATION (NOV)

This letter provides our reply to the subject NOV transmitted by letter from Mark S. Lesser, NRC, to Oliver D. Kingsley,

TVA, dated April 15, 1996.

This NOV involved a failure to follow procedures during maintenance on a core spray valve.

TVA admits the violation.

The enclosure provides our response to the NOV.

No commitments are made in this letter. If you have any questions regarding this reply, please contact Pedro Salas at (205) 729-2636.

Sincerely, Enclosure cc:

See page 2

".OQ3 04 9605200433 960514 PDR ADOCK 05000259 8

PDa

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U.S. Nuclear Regulatory Commission Page 2

May 14, 1996 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 AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1~

2~

AND 3 INSPECTION REPORT NUMBER 50 259'0 260/

50 296/96-03 REPLY TO NOTICE OF VIOLATION (NOV)

RESTATEMENT OF THE VIOLATION "During an NRC inspection conducted on February 4

March 16,

1996, a violation of NRC requirements was identified.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions",

NUREG 1600, the violation is listed below:

Technical Specification 6.8.1.1.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.

Paragraph 9 of Appendix A of Regulatory Guide 1.33 recommends procedures for performing maintenance.

SSP-2.1, Site Procedures

Program, step 3.2.B, states that each step of a "Continuous Use" procedure is to be signed off as complete before proceeding to the next step.

ECI OOO-MOV001, Maintenance For Limitorque Motor Operated Valves, is a "Continuous Use" procedure.

Contrary to the above, on February 29, 1996, written procedures were not implemented during maintenance activities on core spray loop test valve 2-FCV-75-22.

Steps of procedure ECI-0-000-MOV001 were not signed off as complete before proceeding to the next step.

This is a Severity Level IV violation (Supplement I)."

TVA'S REPLY TO THE VIOLATION 1.

Reason For The Violation This violation was caused by personnel error.

Specifically, individuals responsible for signing the procedure steps failed to sign the steps as required following completion of the individual activities.

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2.

Corrective Actions Taken And Results Achieved As an immediate corrective action the appropriate steps of the procedure were signed.

Also, appropriate personnel corrective actions were taken with the individuals involved in this event.

These individuals then briefed other craftsmen on this event, the importance of following procedures, and the need to appropriately document completion of work activities.

Because the procedure did not meet the criteria for being a

"Continuous Use" procedure (the procedure was classified

. incorrectly), it was revised and redesignated as a

"Reference Use" procedure (i.e.,

no longer requires each step to be signed prior to proceeding to the next step).

In light of this event and previous events that involved Maintenance personnel and procedure adherence,'aintenance management has taken several steps to improve procedure adherence.

For example, Maintenance has developed quick-reference cards for Maintenance craftsmen that list, among other things, management.

expectations for attention to detail and procedure adherence.

Maintenance management also continues to stress attention to detail and procedure adherence during their daily debriefs with supervisors and craft personnel.

Maintenance management has conducted additional meetings and coaching sessions with Maintenance craft personnel to stress procedure adherence.

During some of these

sessions, craft personnel involved in the incidents brief their peers on the specific incidents and lessons learned.

3.

Corrective Ste s That

[Have Been Or] Will Be Taken To Avoid Furt er Vxo atxons Broader steps to increase the accountability for human performance improvements will be coordinated through the BFN Human Performance Quality Council.

The council was organized in August 1995 with the responsibility to follow up on recommendations identified by an incident investigation team in July 1994 in response to maintenance related issues.

TVA agrees with NRC that "implementation progress appears to have been slowed during the final stages of Unit 3 recovery."

In response, the council was reorganized on March 1996.

The council will assume overall responsibility for managing site initiatives to improve personnel performance and to be a springboard for new ideas and initiatives to enhance performance and reduce errors,

'Some of these events are discussed in the inspection report forwarding this NOV.

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keeping management focus on human performance issues.

'Specific corrective actions are being identified and schedules established to resolve outstanding issues identified following the July 1994 investigation.

One item of note being monitored by the council is the simplification of cumbersome maintenance procedures.

TVA will charter a team of management and craft personnel to perform a review of high-use maintenance procedures.

The purpose of this review will be to identify any problems with the level-of-use classification (e.g.,

continuous use),

use of sign-offs and verifications, duplication of/with work order steps, and user-friendliness.

TVA expects to complete this action by late 1996.

TVA is also developing a long-term technical procedure improvement project using a joint effort from TVA's corporate and site maintenance organizations.

This program is designed to optimize maintenance and modifications technical procedures by eliminating unused or unnecessary procedures, reducing duplication and complexity, improving the user-friendliness of the procedures, making the procedures self-sufficient through reduction of" cascade effects (branching to other procedures),

and standardizing procedures for multi-site applications.

The actions discussed above are voluntary improvements initiated by TVA.

These actions are not regulatory commitments.

4.

Date When Full Co liance Mill Be Achieved TVA is in full compliance.

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