ML18038B818
| ML18038B818 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/26/1997 |
| From: | Crane C TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9703040223 | |
| Download: ML18038B818 (18) | |
Text
CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
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ACCESSION NBR:9703040223
'DOC.DATE: 97/02/26 NOTARIZED: NO DOCKET 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 AUTHOR AFFILIATION CRANE,C.M.
. Tennessee Valley Authority RECZP.NAME RECIPIENT AFFILIATION.
Document Control Branch (Document Control Desk)
SUBJECT:
, Responds to.NRC 970127 ltr re violations noted in insp repts 50-259/96-13,50-260/96-13 a 50-296/96-13.Correcti;ve actions:
cover, over spent fuel pool was removed.
DISTRIBUTION CODE:
IE01D
'COPIES RECEIVED:LTR
- ENCL'IZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
E INTERNAL,:
RECIPIENT
'ID CODE/NAME PD2-3-PD ACRS AEOD TC ILE -C~EW NRR/DRCH/HHFB
.NRR/DRPM/PERB OE DIR.
RGN2 FILE 01 COPIES LTTR ENCL 1
1 2
2 1
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RECIPIENT ID CODE/NAME
,WILLIAMSgJ.
AEOD/SPD/RAB DEDRO'RR/DISP/PIPB NRR/DRPM/PECB.
NUDOCS-ABSTRACT OGC/HDS3, COPIES LTTR ENCL 1
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1 l.
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EXTERNAL
-LITCO BRYCEg J H
NRC PDR 1
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'NUDOCS FULLTEXT 1
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NOTE TO ALL "RIDS" RECIPIENTS:
t PLEASE HELP US TO REDUCE WASTE!
CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SD-5(EXT. 415-2083)'O 'ELIMINATE YOUR NAME.FROM DISTRIBUTION LISTS FOR DOCUMENTS'.YOU DON'T NEED!
I TOTAL NUMBER OF 'COPIES REQUIRED:
LTTR 20'ENCL 20
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Tennessee Valley Authority, Post Offce Box 2000, Decatur, Alabama 35609-2000 Christopher M. (Chris) Crane Vice President, Browns Ferry Nuclear Plant February 26, 1997 U.
S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C'.
20555 10 CFR 2. 201 Gentleman:
In the Matter, of Tennessee Valley Authority I
Docket Nos.
50-259
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50-260 50-296 BROWNS FERRY NUCLEAR, PLANT (BFN) - NRC INSPECTION REPORT 50 259 r 50 2 60 'r '0 296/96 13 REPLY TO NOTICE 'OF VIOLA'TION (NOV)
This letter provides o'ur reply to the subject NOV transmitted by letter from M'. S. Lesser, NRC, to 0.
D. Kingsley Jr.,
- TVA, dated January 27, 1997:
Two violations of NRC requirements.
were identified.
The first vi'olation involved inadequate work control during placement of a cover over the Unit 2 spent fuel pool.
The second violation addressed two examples of inadequate procedures which resulte'd in an uncontrolled high radiation area and the subsequent unplanned exposure of.
.personnel.
'TVA admits these violations.
tt703040223'70226
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U.'S. Nuclear Regulatory Commission Page 2
February 26,, 1997 The enclosure contains our reply to the NOV.
There are no commitments contained in this reply. If you have any questions, please contact me at (205). 729-3675.
Sincerely,.
C. M.
C ane Enclosure cc:
See page 3
Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, 'Suite 2900
- Atlanta, Georgia 30323 Mr. Mark S. Lesser, Branch Chief U.S..Nuclear Re'gulatory Commission Region II 101 Ma'ri'etta 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 g 2 ~
AND 3 INSPECTION 'REPORT NUMBER 50 259 / 50 260 ~ 50 296/96 13 REPLY TO NOTICE OF VIOLATION (NOV)
RE TATEMENT F VI LATI N A "Technical Specification 6.8.1.l.a requires 'that written procedures shall be established, implemented, and'aintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978; Paragraph 9(e) of Appendix A of Regulatory Guide 1.33 recommends procedures for control of maintenance.
Site Standard Practice procedure SSP-7.3 Work Control, Revision 15, requires control of any work activity which can change or can; have the potential to change 'a component, system or unit configuration.
Section 3.2.1.A requires that an initiator of a work activity is to prepare a.work request for activity performance and after review by the initiator's supervisor, this request is to be forwarded to Operations for further review.
Operations review, according to Section 3.2.1.B of SSP-7.1, affords plant/unit operations an assessment of potential impacts of the activity on. the unit operation.
Contrary to the above, on December 12,
- 1996, a work request was not prepared and therefore, an assessment of potential impacts was not conducted for a tailored, tarpaulin cover erected over and around the upper surface area of the Unit 2 spent fuel pool.
This is a Severity Level IV violation (Supplement I), applicable.
to Unit 2 only.'"
TVA'EPLY TO THE VI LATION 1,.RsnFrThVi 1 inA The root cause of this violation was a failure to fully implement Site Standard Practice SSP-6.2, Maintenance Management System.
Specifically, the individuals involved in installing a cover over the Unit 2 Spent Fuel Pool failed to initiate a work activity document, Work Request (WR), in accordance
.with SSP-6.2.
Site Standard Practice-6.2 requires in part for maintenance activities such as k
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installing a cover over the spent fuel pools, a
WR be initiated, planned, completed, and tracked utilizing the Work Request/Work Order process.
Site.Standard Practice-12.8, Foreign Material Exclusion, establishes controls to prevent the intrusion of foreign material into an open plant system during modifications, maintenance,
- repairs, and inspections.
FME controls are normally implemented as part of a work activity document, Work Order,-that 'is issued in accordance with SSP-6.2 and processed in accordance with SSP-7,. 1, Work Control.
Prior to the violation, TVA planned to perform a maintenance activity that would resolve a.paint adhesion problem on'he spent fuel pool/refuel floor room ceiling.
- However, due to equipment constraints, the activity was de'layed.
Management
- decided, in order to keep paint from falling'into the Unit 2 Spent Fuel Pool, a protective cover would be erected over the pool.
Station personnel installing the cover-over the spent fuel pool failed to recognize.that the installation could affect spent fuel pool system performance and therefore, did not implement the Maintenance Management System'in accordance with.SSP-6.2 and Work Control Process in. accordance with
, SSP-7.1.
Consequently, an assessment of the impact on unit operation was not performed.
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1 A hi v The cover over the spent fuel pool was removed.
The Maintenance and Modifications Manager counseled Modification and refuel floor supervision regarding his expectations that all maintenance work activities be planned and implemented in accordance with,established site procedures.
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Pr v n R
rr n To heighten awareness of personnel, TVA'as issued a sit'e bulletin describing the issues leading to this violation.
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TVA will review SSP-6.2, Maintenance Management
- System, and as required, clarify the'ork control requirements for refuel floor maintenance activities V
D Wh n Full om li n Will B A hi v TVA is in full compliance.
'This corrective action is considered an enhancement and not E-3
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RE TATEMENT F VI LATI N B
".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 7 of Appendix A of Regulatory Guide 1.33 recommends procedures for control of radioactivity.
Operating Instruction 3-0I-6, Feedwater Heating and Misc, Drains
- System, Revision 7, provides Precautions and Limitations, Prestartup/Standby Readiness Requirements, and procedural steps for operation of the Feedwater Heating System.
,Site Standard Practice procedure SSP-12.1, Conduct of Operations, Revision 30, states that radiological.control personnel should be informed prior to evolutions or activities that have a potential to significantly change radiological conditions in the plant.
Contrary to the above:
1.
Operating Instruction 3-0I-6, Feedwater Heating and Misc Drains System, Revision 7, was inadequate to ensure radiological control personnel were notified of changing plant conditions which caused an unanticipated'ise in area radiation levels as evidenced by identification of an uncontrolled locked high radiation area on December 27, 1996.
2.
Site Standard Practice procedure SSP-12.1, Conduct of Operations, Revision 30, was inadequate to ensure that unit radiological control personnel were informed prior to evolutions or activities which have the potential to significantly. change radiological.conditions in the'lant a'
evidenced by the identification of an uncontrolled locked high radiation area in December 27, 1996.
'This is a Severity Level IV violation (Supplement I), applicable to Unit 3 only."
TVA'EPLY TO THE. VIOLATI N B EXAMPLE 1 1.
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n For Th Vi la i n This example resulted from. an inadequate guidance provided in Operating Instruction (OI) 3-0I-6, Feedwater Heating and E-4
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Misc Drains System.
Sufficient administrative controls were not in place to ensure that an area in the Unit 3 Turbine Building, the High Pressure Heater
- Room, was controlled as a
High Radiation Area during the performance of an evolution that caused a change in radiological conditions.
Specifically, the high pressure heater room is normally controlled as a locked high radiation area during power
. operation.
The heaters were isolated for a maintenance activity that reduced the radiation levels in the room.
Following-the maintenance activity, the heaters were being returned to service, and the area radiation levels increased.
During this evolution, 3-0I-6, Feedwater Heating and Misc Drains System, was in use.
However, it did not contain steps for notification of Radiological Control personnel prior making changes in'ystem configuration that caused a significant rise in the area radiation levels.
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1 Ahiv The Precaution.and Limitation Section 'of 3-OI;6, Feedwater Heating and Misc Drains System, has been revised, adding a
statement to notify Radiological Control personnel prior to" making changes in Feedwater Heating System alignments which could cause a rise in area radiation levels.
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Operating instructio'ns for other systems for which a change in system configuration. could have the potential to cause a
rise in area radiation levels were reviewed and
'ppr'opriately revised.
4.
Dat Wh n Full m lian Will B A hi v TVA is in full compliance.
TVA'EPLY TO THE VI LATI N B EXAMPLE 2 1..
R n F r The Vi la ion, This example resulted from inadequate procedural guida'nce for providing information to radiological'ontrol personnel prior to an evolution that significantly changed radiological conditions in the plant; Specifically, SSP-E-5
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12.1, Conduct of Operations, section 3.4.5.G states in'art:
Radiological control personnel ~~ be informed prior to evolutions or activities that -have a potential to significantly change radiological conditions in the plant.
Site Standard Practice-2.2, Writing Procedures, denotes the word "should," as a recommendation.
The word "shall" is used to denote a requirement.
Utilization. of the word "shall" would have placed the correct emphasis on the requirement.
2.
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A hi v Site Standard Practice SSP-12.1, Conduct of Operations, was revised to ensure that plant radiological personnel are informed prior to evolutions or activities which have the potential to significantly change radiological conditions.
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'No further corrective actions are required.
O'.
D Wh n F ll om li n Will B A hi 0
TVA is in full compliance.
i ional Information A r in Li n
'Ex i n n Pr It can:be noted that in Inspection. Report 96-13, NRC stated, the licensee's corrective actions failed to specifically address licensee expectations'or pre-job briefings and how those expectations. would be conveyed to the licensee's staff.
Site Standard PraCtice-12.1, Conduct of.Operations, section 3.6.1.A states in part, The Shift manager/Unit supervisor shall conduct a
preevolution briefing 'with all individuals involved in an evolution that involves more than one department.
Those responsible for the 'pre-.job briefings prior to 'the evolution leading to the violation, received personnel corrective action.in accordance with TVA poli.:cy.
One of the aspects of the action addressed a failure t'o include all personnel involved.in the evolution in the pre-.job briefing.
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