ML18038B983
| ML18038B983 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/07/1997 |
| From: | Crane C TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-259-97-09, 50-259-97-9, 50-260-97-09, 50-260-97-9, 50-296-97-09, 50-296-97-9, NUDOCS 9711170188 | |
| Download: ML18038B983 (20) | |
Text
CATEGORY 1 REGULATORY INFORMATION DZSTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9711170188 DOC.DATE: 97/11/07 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 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION CRANE,C.M.
Tennessee Valley Authority RECIP.NAME
'ECIPZENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 971008 ltr re violations noted in insp repts 50-259/97-09,50-260/97-09 Ec 50-296/97-09,respectively.
Corrective actions:added snubber R suppression pool to reactor bldg vacuum breaker surveillances.
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1 Tennessee Valley Authority. Post Otfice Box 2000. Decatur. Atabaina 35609 2000 Christopher M. (Chris) Crane Vice President, Brmvns Fe.ry Nuctear Rant November 7,
1997 U.
S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Gentleman:
10 CFR 2. 201 In the Hatter of.
Tennessee Valley Authority Docket Nos.
50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN)
NRC INSPECTION REPORT 50 259 r 50 260 r 50 296/97-09 REPLY TO NOTICE OF VIOLATION (NOV)
This letter provides TVA's reply to the subject NOV transmitted by letter from Jon R. Johnson, NRC, to O.
D.
Kingsley Jr.,
TVA, dated October 8,
1997.
In the letter, two violations of NRC requirements were identified.
The first violation involved the testing of snubbers under conditions other than those stated in the Technical Specifications.
The second violation was cited for failure to correctly implement the BFN scaffolding procedure.
TVA admits these violations.
Enclosure 1 contains the reply to the NOVs.
Enclosure 2
contains commitments made in this reply. If you have any questions, please contact me at (205) 729-3675.
t 97iii70i88 97ii07 PDR ADOCK 05000259 8
PDR illliillllllllillllillillllllllllllllll
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U.S. Nuclear Regulatory Commission Page 2
November 7,
1997 Enclosure
.cc (Enclosure):
Regional Administrator U.S. Nuclear Regulatory Commission Region II 61 Forsyth Street S.W.
Suite 23T85
- Atlanta, Georgia 30303 Mr. Mark S. Lesser, Branch Chief U.S. Nuclear Regulatory Commission Region II 61 Forsyth Street S.W.
Suite 23T85
- Atlanta, Georgia 30303 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
ENCLOSURE 1
TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNI,TS 1 g 2 ~
AND 3 INSPECTION REPORT NUMBER 50 259 g
50 260 /
50 296/97 09 REPLY,TO NOTICE OF VIOLATION (NOV)
RESTATEMENT OF VIOLATION A "During an NRC inspection conducted on August 3
September 13,
- 1997, two violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,," NUREG-1600, the violations are listed below:
A.
Technical Specification (TS) 4.6.H.4 which addresses snubber functional testing scheduling, lot size, and composition, states that during each refueling outage, a
representative sample of 10 percent of the total of each type, of safety-related snubbers in use in the plant shall be functionally tested either in place or in a bench test.
Contrary to the above, snubber functional testing was not being performed during refueling outages.
For example, snubber 2-SNUB-063-5001, associated with the Unit 2 standby liquid control system, was removed and functionally tested on September 9,
1997, with Unit 2 operating at power.
In previous refueling outages, numerous snubbers were functionally tested before the outage
- began, consequently, the required testing was not completed during the refueling outage.
The practice of performing snubber functional testing at other than refueling outage conditions has been utilized at Browns Ferry for at least the last two years.
This is a Severity Level IV Violation (Supplement I) ".
0
TVA's REPLY TO VIOLATION A 1.
Reason'For Violation A The root cause for not performing the TS surveillances within the correct time frame was the ineffective control of outage schedules.
Specifically, Work Control personnel were not properly instructed to ensure that TS surveillances were incorporated in refueling outage schedules.
Addition'ally, Site Standard Practice (SSP)-8.2, Surveillance Testing
- Program, Section 3.4.3.D states, in part, a; special surveillance schedule will be provided for all tests required to be completed during refueling outages
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The snubber testing was.not included in this schedule.
This snubber scheduling condition existed for Unit 2 since the Unit 2, cycle 8 outage (March 23, 1996),
during the Unit 3, cycle 7 outage (February 22, 1997), until the Unit 2, cycle 9 outage, when the snubber TS surveillances were incorporated into the refueling outage schedules on September 11, 1997.
As.a result of the snubber functional testing oversight, TVA identified a second similar event for testing vacuum breakers.
As with the snubb'er event discussed
- above, SSP-8.2, Section 3'.3 AD, was not followed.
During the review of a request to perform Unit 2 suppression chamber to reactor building vacuum breaker cycling while the plant was at power, a conflict was identified with TS 4.7'.A.3.b.
This TS requires that:
"a visual examination and determination that the force required to open each vacuum breaker (check valve) does not exceed 0.5 psid will be made each refueling outage."
TVA reviewed past performances of the vacuum breaker surveillances, and the review revealed that these'urveillances had been performed as ASME,Section XI tests on a quarterly basis but'ad not been performed during some refueling outages.
This vacuum breaker scheduling condition existed for Unit 2'ince the Unit 2, cycle 7 outage (October 1,
1994),
during the Unit 3, cycle 7 outage (February 22, 1997), until the Unit 2, cycle 9 outage, when the vacuum breaker TS surveillances were incorporated into the refueling outage schedules on September 19, 1997.
2.
Corrective Ste s Taken And Results Achieved The Scheduling organization incorporated the snubber and the suppression pool to reactor building vacuum breaker
surveillances into the Unit 2, cycle 9 refueling outage schedule.
3.
Corrective Ste s T?iat
[Have Been Or] Will Be Taken To Prevent Recurrence A review of the surveillance program was initiated to verify that other TS surveillances were incorporated into refueling outage schedules.
Based on this review, it was confirmed that these two surveillances were the only surveillances that were not incorporated in refueling outage schedules.
Snubber and suppression pool to reactor building vacuum breaker surveillance instructions were incorporated in the standard refueling outage surveillance schedule to ensure that these activities are performed in future refueling outages.
Work Control management willensure proper policy,
- guidance, expectations, and job performance standards are provided to Work Control personnel in the outage organization.
L Date When Full Com liance Will Be Achieved TVA is in full compliance.
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II.
RESTATEMENT OF VIOLATION B "Technical Specification (TS) 6.8.1.la 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 that can affect safety related equipment.
Section 5.1 of Technical Instruction (TI) O-TI-264, Scaffolds and Temporary Platforms, states that prior to and during erection, Appendix M, Scaffolding/Temporary Platform Erection Checklist, shall be completed and maintained with the scaffold platform log.
Section 2.7.7 of 0-TI-264 states, in part, if the required clearance cannot be physically achieved, Site Engineering evaluation and approval shall be obtained and documented prior to erecting the portion of the scaffold in which the clearance cannot be achieved.
Section 2.9.4 of Appendix L of 0-TI-264 requires, in part that after the Site Engineering evaluation has been completed and the scaffold erected, the responsible field
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engineer shall inspect the scaffold or platform per the Site Engineering evaluation requirements.
General precaution 4.4 and step 7.11.4 of 0-TI-264 require that the areas around scaffolds which can be used for handholds or footholds shall be posted with caution signs and/or tape to avoid use'as handholds or footholds.
Contrary to the above, written procedures for performing maintenance which can affect safety related equipment were not properly implemented in that:
A scaffold erection checklist was not completed for Scaffold 2322 and checklists for several other scaffolds were not completed properly; several scaffolds near safety systems were erected in which the minimum clearances could physically have been achieved but were not; the responsible field engineer flailed to note that Scaffold 2322 did not have the minimum clearances specified in the Site Engineering evaluation (in respect to the suppression chamber outside surface);
and numerous potential handholds and footholds located near scaffolds in the Unit 2 reactor building were not posted with caution tags or tape.'hese conditions were identified on August 26, 1997.
e This is a repeat Severity Level IV Violation (Supplement I)."
TVA's REPLY TO VIOLATION B Reason For The Violation The root cause of this violation was personnel error for failure to follow procedure.
Specifically, the guidance provided by O-TI-264, Scaffolds and Temporary Platforms, Revision 12,.
was not followed during the erection of scaffolding by TVA.
In the instance involving Scaffold 2322, and others in which the scaffolding checklist was not properly completed, the erecting foremen failed to ensure that the scaffold erection checklist was completed.
In the instance in which Scaffold 2322 could not be erected maintaining minimum clearance requirements specified in 0-TI-264, a Scaffold Evaluation, Appendix N 'of O-TI-264, was performed.
The evaluation required that the scaffold side-to-side clearance be greater than one inch and members pointed at the suppression chamber have a minimum clearance of four inches.
However, contrary to the requirements of the evaluation, a support member was identified pointing
il 0
towards the Unit 2 suppression
- chamber, at a distance of less than four inches.
Craft personnel erecting Scaffol'd 2322 failed to meet the Scaffolding Evaluation clearance requirements.
The responsible field engineer failed to ensure that all of the dimensions specified on the Scaffolding Evaluation were met.
For the other events involving the scaffolding being erected such that the minimum clearances from safety systems could have been attained and were not, the craftsmen and the foreman failed to erect the scaffolding in a manner that the required clearances could be obtained.
The erecting foreman also failed to provide the required postings on areas around scaffolds which could be used for handholds or footholds.
Consequently, potential hand ho'lds and footholds located near scaffolds were not identified by caution tags or tape.
TVA attributes the aforementioned failures to follow procedure identified in this violation to ineffective oversight by maintenance supervision of scaffolding activities.
TVA also found that 0-TI-264 was cumbersome, thus, contributing to failures to follow the procedure.
Scaffold 2322, located near the Unit 2 suppression
- chamber, was dismantled.
Other scaffolding near the suppression chamber was inspected for similar issues.
None were identified.
For the events involving the scaffolding being erected such that the. minimum clearances from safety systems could have been attained and were not, a Scaffolding Evaluation was performed that ensured from a safety standpoint, the placement of the scaffold was acceptable.
To ensure scaffolding erected in Class I areas of the plant met the requirements of O-TI-264, a walkdown review of other scaffolding platforms was performed.
Deficiencies identified during the walkdown were co=rected.
A work standdown with those involved in erection of scaffolding platforms was held.
Meetings were held with Supervisors and craftsman responsible for scaffold erection in which compliance with 0-TI-264 was emphasized.
Also, to further ensure compliance with 0-TI-264 during the Unit 2 Cycle 9 outage, an
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0 e
individual knowledgeable in the requirements of the TI, was designated as the field engineer responsible for independent inspections of scaffolding.
For those involved in the multiple instances of failure to comply with O-TI-264, including failure to provide posting for potential handholds and footholds, appropriate disciplinary actions were administered.
3.
Corrective Ste s That
[Have Been Or] Will Be Taken To Prevent Recurrence TVA has revised 0-TI-264.
The revision simplified the procedure and removed unnecessary information.
By simplifying the procedure compliance with the requirements should be improved.
The revision also requires the involvement of Operations in the determination of operability of components adjacent to scaffolding erected in Class 1 areas.
Appropriate personnel were trained on the revised requirements of the TI.
Scaffolding exsection is being monitored for compliance with 0-TI-264 by support group supervision.
This group comprises a Lead Foreman, a Supervisor, and the Task Manager.
They ensure compliance with 0-TI-264.
TVA will transfer the above monitoring function to the Maintenance/Modifications Self-Assessment program.
This action will be completed by January 16, 1998'.
This. reply and the applicable pages from the NOV will become part of indoctrination training for those involved in the erection of scaffolding.
This action will be completed by January 16, 1998.
Date When Full Com liance Will Be Achieved TVA is in full compliance.
'his action is being tracked by TVA's Corrective Action program and is not considered a regulatory commitmcnt.
0
ENCLOSURE 2
TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1'
2 I AND 3 INSPECTION REPORT NUMBER 50 259 I 50 260 I 50 296/97 09 REPLY TO NOTICE OF VIOLATION (NOV)
COMMITMENTS VIOLATION A Work Control Management will ensure proper policy, guidance expectations, and job performance standards are prove'.ded to Work Control personnel in the outage organization.
This guidance will be completed by March 16, 1998.
This commitment is being tracked by LER 50-260/97004 VIOLATION B This reply and the applicable pages from the NOV will become part of indoctrination training for those involved in the erection of scaffolding.
This action will be completed by January 16, 1998.
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