ML18058B963
| ML18058B963 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/24/1992 |
| From: | Zeringue O TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9206290319 | |
| Download: ML18058B963 (3) | |
Text
Tennessee Valley Authority, Post Office Box 2000. Decatur. 'Alabama 35609
- 0. J. 'Ike' Zeringue Vice President, Browns Ferry Operations JUN 2 4 199Z U ~ S. Nuclear Regulatory Cmmnission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
Jn the Matter of Tennessee Valley Authority
)
)
Docket Nos. 50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - NRC INSPECTION REPORT 50-259; 260,
. 296/92-03.:.. SUPPLEMENTAL RESPONSE TO NOTICE.OF VIOLATION (NOV)
On May 1, 1992, TVA representatives met with the NRC Senior Resident*
Inspector to discuss TVA's response to NOV 92-03.
The NOV was issued with two examples for failure to follow procedure.
The first example
. involved the inadvertent start of a diesel generator during the performance of a surveillanc~ (SI) and the second example involved the misalignment of a spent.fuel transfer c~nal gate.
The purpose of the discussion was to address three inspector concerns identified in the body of the inspection report related to the inadvertent sta~t of.the diesel
. genera.tor during the performance of an SI.
.This supplem*entai response addresses these concerns.
The inspector's first concern involved a corrective action in Revision 0 of the Incident Investigation (II) that stated that TVA :would review the possibility of allowing the craft performing the work activities to hold equipment clearances.
BFN's present practice allows foremen and general foremen to hold clearances.
TVA has contacted several plants in the industry.
These contacts show that a broad range of methods exist for holding and transferring clearances, including allowing the use of craftsmen.
However, TVA does not at the present have plans to allow
- craftsmen to hold clearances at BFN.
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9206290319 920624 PDR ADOCK 05000259 PDR G
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2 U.S. Nuclear Regulatory Commission JUN 2 4 1992 The inspector's.second concern was related to the timeliness of implementing corrective actions since theJr due dates were*l;>eyond the date for testing additional diesel generators. Specifically, the staff felt that TVA did not have a full llllderstanding of the *problems that.
occurred during testing of the diesel generator and therefore should not have begllll testing any additional diesel generators.* The inspector's opinion is based on Revision 0 of the II, since it did.not address whether the worlanan failed to follow the steps as written in the SI during equipment manipulations or the cause of a diesel generator overspeed event.
TVA agrees that Revision 0 of the II did not adequately address either the cause of the diesel generator overspeed event or that the worlanan
- railed to follow the steps as written.in the SI during*equipment manipulations.
TVA revised the II to address-both issues.
As discussed in the Ma,y 8, 1992 letter. to NRC, TVA has recognized that certain IIs were lacking the necessary level of self-critical reviews of events and TVA will continue to stress the need for self-critical. evaluati_ons through the Plant Evaluation Review Panel and management review of Ils.
The inspe.ctor's final concern involved Site Standard Practice (SSP) 12.3, "Equipment Clearance Procedure," Step 3.1.4..
This step provides specif~c cautions to be*used during clearances developed for testing.
TYA's response to the NOV stated that this section of SSP-12.3 did not apply to Sis.but only to special.tests. However, the inspector noted that if the worlanarihad foilowed the.provisions of Section 3.1.4 when he elected to implement the procedure in a different method than was written then the event would not have occurred. Specifically, if "yellow tags" had been ut11ized as described in SSP 12.3, Step 3.1.4; then the additional requirements associated with the use of the "yellow tags" would have prevented this event.
As discussed in subject response, TVA ma.intains. that _if the worlanan had
- implemented the steps in this SI as written then this event would not have occurred, TvA acknowledges that the use of the "yellow tags" would have prevented the *event.
However, use of the "yellow tags"*would have
.constituted a deviation from the requirements or' the SI 'and TVA does not condone deviations from established work practices.
TVA developed Step 3.1.4 to provide guidance on the development and removal of clearances for special tests; such as hipot tests, megger tests, and hydrostatic.
tests, not to provide a backup in the event personnel deviate from approved plant procedures.
3 U.S. Nuclear Regulatory Conunission
'JUN 2 4 1992 In sununary, TVA agrees.with the inspector that Revision 0 of this II was lacking the necessary level of self-critical reviews.for this event and TVA will continue to stress the need for self-critical evaluations
- through the Plant Evaluation Review Panel and management review of !Is...
Sincerely,
. 4!Jdlit!f Jll a:!/ Zeringue cc:
NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box.637 Athens, Alabama 35611 Mr. ThierryM. Ross, Project Manager U.S. Nuclear Regulatory Commii;;sion One White Flint, North 11555 Rockville Pike-Rockville, Maryland 20852 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Conunission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323