ML18065B281
| ML18065B281 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/13/1998 |
| From: | Crane E TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-259-97-12, 50-260-97-12, 50-296-97-12, NUDOCS 9803230172 | |
| Download: ML18065B281 (6) | |
Text
Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 Christopher M. (Chris) Crane Vice President. Browns Ferry Nuclear Plant March 13, 1998 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentleman:
In the Matter of Tennessee Valley Authority 10 CFR 2.201 Docket Nos.
50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) -
NRC INSPECTION REPORT 50-259, 50-260, 50-296/97 REPLY TO NOTICE OF VIOLATION (NOV)
This letter provides TVA's reply i:o the subject NOV transmitted by letter from Mr. M. S. Lesser, NRC, to Mr. 0. J. Zeringue, TVA, dated February 12, 1998.
In the letter, a violation of NRC requirements was identified.
The violation involved the failure to follow procedure in that an adverse condition was not promptly reported to the appropriate level of management.
TVA admits the violation.
The enclosure contains TVA's reply to the NOV.
No commitments are contained within this reply.
If you have any questions, please contact me at i205) 729-3675.
Sincerely,
/ !
Enclosure
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U.S. Nuclear Regulatory Commission Page 2
- March 13, 1998 Enclosure cc (Enclosure):
Mr. A. W. De Agazio, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 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
ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 INSPECTION REPORT NUMBER 50-259, 50-260, 50-296/97-12 REPLY TO NOTICE OF VIOLATION (NOV)
RESTATEMENT OF VIOLATION A "During an NRC inspection conducted on December 7, 1997 -
January 17, 1998, 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:
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Site Standard Practice SSP-3.4, Corrective Action Program, Revision 18B, Section 3.0 states that it is the responsibility of all personnel to promptly documeht arid report conditions/deficiencies including adverse conditions to the appropriate organization's Departme~t Managers for evaluation and disposition.
Section 3.1.A of the procedure states that personnel shall promptly report conditions/deficiencies including adverse conditions using the appropriate ACP [Administrative Control Process] as identified in this procedure.
Contrary to the above, On January 13, 1998, an adverse condition was not promptly documented and reported to the appropriate organization's Department Manager for evaluation and disposition.
The adverse condition was identified by the NRC while observing maintenance activities on the 3C diesel *generator but was not properly documented until January 22, 1998.
This is a Severity Level IV Violation (Supplement I)".
TVA's REPLY TO THE VIOLATION
- 1.
Reason For The Violation On January 13, 1998, a standby emerg~ncy diesel generator (EDG) twelve-year inspection on EDG 3C was in piogress.
Engine Systems Inc. (ESI) was assisting TVA with the inspection.
ESI is an authorized distributor of Electro-Motive Division (EMD) diesel engine power p~oducts manufactured by EMD of General Motor Corporation.
ESI performs maintenance on General Motors diesel generators in 17 states along the east coast, the Caribbean, and for nuclear power plants worldwide.
During the inspection, an ESI specialist did not fully remove one of the two 3C EDG fuel pump suction strainer covers to inspect the strainer.
In the twelve-year EDG inspection procedure (MPI-0-082-INSOOS), Steps 7.17.1 and 7.17.2 state *"REMOVE the two strainer cover bolts and washers from each strainer and "REMOVE the strainer covers and elements.
DISCARD o-rings."
The ESI specialist determined that partial removal of the cover was adequate to inspect the strainer element.
The ESI specialist noted no debris on the outside of the strainer element and based on his experience, concluded that no debris would be on the inside of the strainer and, as such, further inspection of the strainer element was not required. Consequently, the strainer cover was partially removed for element inspection.
This failure to fully remove the strainer cover was observed by an NRC inspector.
The inspector confronted the ESI specialist arid informed a TVA foreman of the event.
The ESI specialist also notified the TVA foreman of the even~.
Although the ESI specialist ensured the foreman that no impact could result from the method used to inspect the strainers, the foreman directed the ESI specialist to completely remove of the strainer cover and element.
Since the condition could be immediately corrected under the existing work order, and there was no safety issue, the foreman did not consider it essential to write a Problem Evaluation Report (PER) nor inform Maintenance management of the event.
This is not consistent with TVA management expe~tations for writing PERs regardless of the significance of the issue.
Consequently, the Maintenance Superintendent was not aware of th~~y_en_t when he and the NRC Senior Resident Inspector
-a-1scussed it on the following morning.
The Maintenance Superintendent directed the TVA dayshift EDG inspection Task Manager to write a PER for failure to fully remove the strainer cover.
On January 14, 1998,about 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> following the deficiency, in a nightly telecon between the
ii Maintenance/Modifications Manager, Maintenance
- Superintendent, and the dayshift and nightshift EDG inspection Task Managers, the event was discussed in detail.
At this time, the effects were understood by Maintenance management and corrective actions were discussed.
As a result, the reason for promptly documenting conditions as required by SSP-3.4 (i.e:,
notification of management) was met.
The dayshift EDG inspection Task Manager made a note to write the PER but failed to review his notes prior to leaving the site and did not enter the action into the log book.
The Task Manager subsequently misplaced the note.
Consequently, the Tisk Manager did not write the PER.
On January 22, 1998, the Task Manager was made aware that a PER had not been* written.
The Task Manager wrote the PER.
The cause of the violation was that the foreman inappropriately considered the significance of the issue and did not notify Maintenance management.
The delay in-writing the PER after it was identified was caused by failure of the dayshift EDG inspection Task Manager to enter the action into the logbook.
TVA does not consider this to be indicative of a widespread problem concerning reluctance to write PERs due to the circumstances surrounding this event.
In fact, during the 3C EDG inspection (6 days), 15 PERs were written documenting a range of minor deficiencies.
- 2.
Corrective Steps Taken And Results Achieved MPI~0-082-I~SOOS, steps 7.17.1 and 7.17.2, were re-performed in accordance"with the procedure.
This action was completed prior to NRC notifying the Maintenance Superintendent on January 14, 1998.
A PER was initiated on January 22, 1998.
This action ensured that the condition which did noL affect operability and is not reportable was documented foi trending purposes.
For four days from January 23 through January 26, 1998, Maintenance management presented a memorandum at shift briefings that addressed the conditions of this event.
This memorandum served to re-enforce Maintenance management's
-exp_e.cta ti on to generate PERs regardless of the significance of the event.
i
- 3.
- orre*ctive Steps That [Have Been Or] Will Be Taken To Prevent Recurrence The foreman and Task Manager were counseled as to their responsibility to ensure that conditions are documented in a timely manner.
Maintenance/Modifications personnel were briefed on the requirements of SSP-3.4, Secticn 3.1.A, emphasizing the use of PERs to document deficiencies even when additional corrective actions are not required.
Maintenance/Modifications personnel were briefed on the proper use of log books so that required actions are tracked and dispositioned.
While TVA expects all personnel to write PERs for any adverse condition regardless of significance, TVA recognizes the difficulty of maintaining the sensitivity of all employees to this expectation.
As a result, TVA has issued a site bulletin addressing this event to sensitize plant personnel to management's expectations for generating PERs at BFN.
- 4.
Date When Full Compliance Will Be Achieved TVA is in full compliance.