ML18038B711
| ML18038B711 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/20/1996 |
| From: | Machon R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9606240190 | |
| Download: ML18038B711 (14) | |
Text
CATEGORY j REGULATO INFORMATION DISTRIBUTION YSTEM (RIDS)
ACCESSION NBR:9606240190
'DOC.DATE: 96/06/20
-NOTARIZED: NO
,DOCKET If ACIL: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'UTHOR,AFFILIATION MACHON,R.'D.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk),
SUB'JECT: 'Provides reply to NRC 960521 ltr re v'iolations noted in insp repts 50-259/96-04,,50-260/96-04' 50-296/96-04.C/A:
discontinued fuel movement activities, removed jumpers reconnected control rod position inputs.
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 ILE. CENTER NRR~GH/
B NRR/DRPM/PERB.
OE DIR RGN2 FILE 01 EXTERNAL: LITCO BRYCE,J H
NRC PDR COPIES LTTR ENCL 1
1 2
2 1
1 1
1 1
1 1
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1 1
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1 RECIPIENT ID CODE/NAME WILLIAMSgJ.
AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS3 NOAC COPIES LTTR ENCL 1
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N, NOTE TO ALL "RZDS" RECZPZENTS:
PLEASE HELP US TO REDUCE WASTE!
CONTAC THE DOCUMENT COiNTROL DESi(,
ROOM OWFN SD-S(EXT.
415-20S3)
TO EL iMZNATE YOUR NAMiE FROM DZSTRZBUTZON LZSTS FOR DOCUMENTS YOU GN'T NEE TOTAL NUMBER OF COPIES'EQUIRED:
LTTR 19 ENCL 19
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R. D, Rick: Mac".,on June 20, 1996 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555
Dear Sir:
10 CFR 2.201 BRONNS FERRY NUCLEAR PLANT (BFN) - NRC ZNSPECTZON REPORT 50 259I 50 260I 50 296/96 04 REPLY TO NOTZCE OF VZOLATZON (NOV)
'This letter provides our reply to the subject NOV transmitted by letter from Mark S. Lesser, NRC, to Oliver D. Kingsley,,
TVA, dated May 21, 1996.
This NOV included three violations:
Violation A involved TVA",s discovery of certain Appendix R
noncompliances; Violation B involved movement of fuel with an inoperable refueling interlock; and Violation C involved a failure to follow procedure that resulted in erection of scaffolding within three feet of the 3C Emergency Diesel Generator Field Flash Breaker.
TVA admits these violations.
As noted in,the
- NOV, TVA agrees that Licensee Event Report 260/96001, Revision 1, dated March 26, 1996, provides the information required by 10 CFR 2.201 for Violation A.
Accordingly, the enclosure provides our response to Violations B and C only.
There are no commitments made in this reply-.
If you have any questions regard'ing this reply, please contact Pedro Salas at (205) 729-2636.
Since 1
R'.
'D. Machon Enclosure cc:
See page 2
t
'P606240i90 960620 PDR ADQCK 05000259 8
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U.S.,Nuclear Regulatory Commission Page 2
June 20, 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 1I 2I AND 3 INSPECTION REPORT NUMBER 50 259 I 50 260 I 50 296/96 04 REPLY TO NOTICE OF VIOLATION (NOV)
RESTATEMENT OF VZOLATZON B "Technical Specification 3.10.A.l requires that the required refueling equipment interlocks shall be operable during in-vessel fuel movement with the equipment associated with the interlocks except as specified in 3.10.A.6 and 3.10.A.7.
Contrary to the above, on March 23,
- 1996, the refueling equipment interlocks were not operable during in-vessel fuel movement nor were conditions specified in 3.10.A.6 or 3.10.A.7 met.
This is a Severity Level IV violation (Supplement I), applicable to Unit 2 only."
TVA'S REPLY To'ZOLATZON B 1.
Reason For The Violation This event was caused by improperly implementing the technical specification (TS) requirements for declaring/maintaining the "all rods in" refueling interlock operable.
Plant personnel believed that fully inserting all control rods and.electrically disconnecting their directional contPoi valves satisfied the inferft of the TS for having an operable "all rods in" interlock.
Additionally, TS 3.3.A.2.e requires that control rods whose position cannot be positively determined shall be considered inoperable.
Inoperable control rods are inserted and electrically disarmed per TS 3.3.A.2.b.
These conditions were verified as being met prior to bypassing the full-in position switches for the control rods.
Plant personnel did not consider this interlock inoperable since all 185 control rods were fully inserted and prevented from being withdrawn from the core.
As a result, plant personnel failed to recognize that disabling the control rod position inputs to the "all rods in" refueling interlock functionally disabled the interlock.
2.
Corrective Actions Taken And Results Achieved The immediate corrective actions were to discontinue fuel movement activities, remove the jumpers, and reconnect the control rod position inputs to the "all rods in" refueling interlock.
To prevent recurrence, appropriate personnel corrective actions have been taken with the individuals involved in the preparation of the safety assessments for disabling the interlock and in the decision to move fuel
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with the control rod position inputs disabled.
Additionally, the two procedures that had been revised to allow the interlock to be disabled have since been changed to discontinue this practice.
An assessment of the remaining outage work scope was conducted and no other instances were identified which would have resulted in improper Technical Specification implementation.
3.
Corrective Ste s That
[Have Been Or),Will Be Taken To Avoid Further Violations In addition to the above actions, TVA plans to develop a
briefing paper that discusses this event, the lessons
- learned, management expectations for preparation of safety assessments and safety evaluations, and the need for literal compliance with TS requirements.
TVA plans to distribute this briefing paper to 50.59 qualified individuals at BFN for required review as a Training Dispatch.
TVA also plans to include discussion of this event, the lessons
- learned, and other relevant information in the licensed operator requalification training program.
TVA expects to complete these actions by July 25, 1996.'he actions discussed above are voluntary improvements initiated by TVA.
These actions are not regulatory commitments.
4..
Date When Full Co liance Will Be Achieved TVA is in full compliance.
RESTATEMENT OF VIOLATION C "TS 6.8.1.1.a requires that written procedures shall be estab1~ged, 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 that can affect safety related equipment.
O-TI-264, Scaffolding and Temporary Platforms, step 7.3.15.1, states that no scaffolding/scaffolding access and egress points of platforms shall be erected closer than 3 feet from any access point of electrical boards, electrical panels or panels with electrical devices which will block entrance into the panel or possibly cause inadequate protection of switches from being repositioned, unless specifically permitted by the Shift Operations Supervisor as indicated by signature on the Scaffold Erection Checklist.
'~These additional actions are considered enhancements and are not commitments.
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Contrary to the above, on February 26, 1996,. plant procedure 0-TX'-264'was not properly implemented when scaffolding was erected less than 3 feet from 3C Emergency Diesel Generator field flashing breaker.
On February 29, 1996, this resulted in the 3C Emergency Diesel Generator being inoperable due to an inadvertent mispositioning of the field flashing breaker.
This is a Severity Level IV violation (Supplement I), applicable to Unit 3 only."
TVA' REPLY To VIOLATION C 1.
Reason For The Violation This violation resulted from personnel error.
On February 26,
- 1996, a temporary scaffold was erected in Emergency Diesel Generator (EDG)
Room 3C.
Contrary to the requirements of Technical Instruction O-TI-264, "Scaffolds And Temporary Platforms," the scaffold access and egress point was found approximately two feet from the electrical panel in which the field flashing breaker for EDG 3C is located.
On February 29, 1996, during routine third-shift rounds, an assistant unit operator discovered the field flashing breaker for EDG 3C in the open position, thus rendering the EDG inoperable.
TVA cannot conclusively determine the cause of the mispositioned breaker.
This event was most likely caused by an individual inadvertently bumping the breaker while exiting the scaffolding.
2.
Corrective Actions Taken And Results Achieved TVA declared thy 3C EDG inoperable and returned the breaker to the closed position.
Following this action, the EDG was determined to be operable.
The breaker had been verified closed on the prior third-shift rounds; therefore, the breaker would not have been open more than approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The.other seven diesel generators were operable during this 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.
The scaffolding access ladder was moved to a different location that conformed to the three foot spacing requirements in 0-TI-264.
Additionally, disciplinary action was taken.
3.
Corrective Ste s That
[Have Been Or] Will Be Taken To Avoid Further Violations Craft personnel have been briefed on the specific separation/clearance requirements of 0-TI-264.
Breaker guards will be installed to protect the field flashing breakers for all eight EDGs from accidental opening.
TVA also plans to evaluate other plant equipment to determine if E-3
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I similar protective measures are warranted for other switches.
Additionally, and as noted in TVA's May 14, 1996 response to NOV 50-259, 50-260, and 50-296/96-03, TVA is taking broader steps to improve human performance and increase the accountability for human performance improvements.
These actions are being coordinated by the BFN Human Performance Quality Council.
The council was organized in August 1995 and tasked with following up on recommendations identified by an incident investigation team in July 1994 in response to maintenance related issues.
The council was recently reorganized and now has overall responsibility for managing site initiatives to improve personnel performance.
The council is also expected to encourage new ideas and initiatives to enhance performance and reduce errors, and is also expected to keep management focused on human performance issues.
The actions discussed above are voluntary improvements initiated by TVA.
These 'actions are not regulatory commitments.
4.
Date When Full Co liance Will Be Achieved TVA is in full compliance.
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